OFAC FAQ (Current) # 951 - Counter Terrorism Sanctions (Includes prior versions)

Date issued: Feb. 25 2022

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TURBOFAC Commentary (346 words)

Notes:

1) FAQ Amended on 2-25-2022 to add non-substantive references to GTSR/FTOSR General License 20, to add "so-called Donetsk People’s Republic and Luhansk People’s Republic regions" to the list of comprehensively sanctioned areas, and to remove a paragraph stating that "Transactions or activities that involve [] sanctioned [individuals] persons or property in which such persons have an interest are generally prohibited, unless exempt from regulation or authorized by OFAC." This accounts for the scope of GL 20.

2) This FAQ appears to have been produced for the consumption of regulated persons not intimately familiar with the scope and operation of OFAC-administered sanctions laws. To the extent that anything in the FAQ could be construed as “guidance,” there are two notable aspects of the FAQ.

One is that we can discern that “moving or sending money into and out of Afghanistan”...