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

Date issued: Feb. 25 2022

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (241 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...