OFAC FAQ (Current) # 923 - Ethiopia-Related Sanctions

Date issued: Sep. 17 2021

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TURBOFAC Commentary (980 words)

Notes:

As discussed in the comments to EO 14046, the blocking sanction at section 2(a)(i)(A) is identical to the one at section 1(a)(iv) of EO 13849, except that section 1(b) of EO 14046 explicitly states that “[n]o entity shall be blocked pursuant to this order solely because it is owned in whole or in part, directly or indirectly, by one or more sanctioned persons, unless the entity is itself a sanctioned person and the sanctions in section 2(a)(i)(A) of this order are imposed on the entity.” Note that “sanctioned person” is a defined term in the EO (as it is in EO 13849), and it refers exclusively to persons for whom an “affirmative determination” is made (as opposed to persons blocked by operation of law).

Contrast FAQ # 869, in which OFAC concludes that the...