OFAC FAQ (Current) # 955 - Counter Terrorism Sanctions

Date issued: Feb. 25 2022

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TURBOFAC Commentary (262 words)

Notes:

1) This FAQ appears to be a roundabout way of saying that OFAC-administered contain prohibitions that extend far beyond those imposed by the UN, but at the same time they implement the UN sanctions insofar as they do not authorize transactions that would be prohibited under the UN regime. See UNSCR Resolution 2615 (2021), Related Items for the UNSCR resolution referenced in the FAQ. This is a rare situation in that OFAC has issued GLs and explicitly acknowledges that the GLs “help implement” a UNSC resolution. The following sentence can, arguably and in particular with the reference to “intended to cover”, be read for the proposition that items other than those produced by the USG can serve as interpretative aids for the scope of the GLs:

Specifically, UNSCR 2615 (2021) was intended to cover...