OFAC FAQ (Current) # 931 - Taliban / Haqqani Network-related GLs

Date issued: Feb. 25 2022

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TURBOFAC Commentary (201 words)

Notes:

1) FAQ Amended on 2-25-2022 to add non-substantive references to GTSR/FTOSR General License 20.

2) This FAQ continues OFAC's recent trend of explicitly stating that transactions that are permissible for U.S. persons are not transactions that would (even if they theoretically could) result in the imposition of sanctions on non-U.S. persons whose activities do not otherwise have a U.S. nexus. OFAC makes specific reference to the "significant transaction" standard, but the guidance also applies to the "material assistance" derivative designation criteria found in the GTSR and EO 13224, as amended. Compare FAQ # 867 (Syria secondary sanctions), FAQ # 867 (certain Iranian SDGTs), and FAQ # 545 (Russia-related secondary sanctions). Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative...