OFAC FAQ (Current) # 959 - Counter Terrorism Sanctions

Date issued: Feb. 25 2022

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TURBOFAC Commentary (184 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) 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 (see General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note)). It is not necessarily obvious from the test of GL 19 that the direct payment of the salaries of health care workers would qualify as "[a]ctivities to support humanitarian projects to meet basic human needs in Afghanistan, including...the provision of health services..." This presumably has implications for sectors apart from health care (confirmed in