OFAC FAQ (Current) # 928 - / Haqqani Network-related GLs (PDF contains all versions)

Date issued: Feb. 25 2022

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TURBOFAC Commentary (238 words)

Notes:

1) This FAQ was substantially amended on 2-25-2022 to account for the issuance of GL 20 GTSR/FTOSR General License 20, which appears to cover close to the entirety of what had previously been authorized by GLs 14-19.

2) The FAQ states that GLs 14-20 "do not authorize any debit to a blocked account on the books of a U.S. financial institution". The text of the GLs contain a proviso stating that that they do not authorize "[a]ny debit to an account on the books of a U.S. financial institution of any blocked person". To the extent that "of any blocked person" may be seen as narrower than the full range of accounts blocked due to a blocked person's "interest" therein, this FAQ appears to resolve the ambiguity.

3) The original FAQ contained the...