OFAC FAQ (Current) # 958 - Counter Terrorism Sanctions

Date issued: Feb. 25 2022

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TURBOFAC Commentary (328 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.

1) This FAQ provides some notable examples of transactions that may be "ordinarily incident and necessary to activities authorized by" the relatively standard NGO-related GL (GTSR/FTOSR General License 19). The FAQ has implications for similarly worded GLs (seeGeneral Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note)).

2) In FAQ # 951, OFAC appeared to clarify that the Taliban-related GLs did not authorize transactions involving individual SDNs, i.e. persons that appear on the SDN list because of their Taliban affiliation.

In addition to the Taliban and the Haqqani Network, there are other Afghanistan-related individuals and...