OFAC FAQ (Current) # 963 - Counter Terrorism Sanctions

Date issued: Feb. 25 2022

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TURBOFAC Commentary (278 words)

Notes:

1) FAQ Amended on 2-25-2022 to add non-substantive references to GTSR/FTOSR General License 20.

2) This FAQ appears to be the first of its kind, and has implications beyond shipments of cash “for use in delivering humanitarian assistance”. OFAC says that “cash shipments to Afghanistan may be authorized under General Licenses (GL) 14, GL 18, or GL 19, provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs.” On its face, that may apply to all activities licensed by those GLs.

Because OFAC is interpreting GLs (e.g. GTSR/FTOSR General License 18) that do not have “ordinarily incident” language baked into them, OFAC is necessarily applying the standard “ordinarily incident” interpretive provision of the GTSR (594.405). ...