OFAC FAQ (Current) # 957 - Counter Terrorism Sanctions

Date issued: Feb. 25 2022

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TURBOFAC Commentary (450 words)

Notes:

1) FAQ Amended on 2-25-2022 to add non-substantive references to GTSR/FTOSR General License 20, and note overlap with pre-existing GLs.

2) Read in conjunction with FAQ # 930. The primary purpose of this FAQ appears to be to clarify that "GL 15 also authorizes U.S. persons to engage in transactions or activities that are ordinarily incident and necessary to authorized exports or reexports, including the processing of financial transactions and related clearing and settlement involving privately-owned and state-owned banks in Afghanistan" (emphasis added).

FAQ # 930, by contrast, made reference only to "the processing of financial transactions and related clearing and settlement involving banks in Afghanistan."

The specification is significant, because it implies that "state-owned banks in Afghanistan" are not necessarily blocked persons by virtue of their association with or...