OFAC FAQ (Current) # 949 - Counter Terrorism Sanctions (PDF contains all versions)

Date issued: Feb. 25 2022

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TURBOFAC Commentary (384 words)

Notes:

1) FAQ Amended on 2-25-2022 to add references to GTSR/FTOSR General License 20 and clarifying that it overlaps in scope with other Taliban-related GLs, GL including 16.

The amended GL changes "[t]he Taliban is designated as a Specially Designated Global Terrorist" to "[t]he Taliban are designated as a Specially Designated Global Terrorist". This is a subtle distinction, but presumably aimed at stressing that OFAC regards the Taliban as a group of individuals, rather than just a specific, identifiable entity (like a corporation).

2) Read in conjunction with GTSR/FTOSR General License 16. The first paragraph of the FAQ serves to clarify that Afghanistan is not subject to an embargo. "[H]and-carrying of noncommercial, personal remittances to an individual in...or ordinarily resident in..." a country subject to an "export of services" prohibition is within the scope of such prohibitions....