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876. Do non-U.S. persons risk exposure to sanctions under E.O. 13224, as amended, for engaging in transactions involving Ansarallah, or any entity in which Ansarallah owns a 50 percent or greater interest, that U.S. persons would be authorized to engage in under General Licenses 9, 10, 11, and 12?
Non-U.S. persons may engage in or facilitate transactions involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, without exposure to sanctions under E.O. 13224, as amended, if such activity would be authorized under General Licenses (GLs) 9, 10, 11, and 12 if engaged in by a U.S. person. Activity that would be authorized by GLs 9, 10, 11, and 12 if engaged in by a U.S. person would not be considered “significant” for the purposes of a secondary sanctions determination under E.O. 13224, as amended.
Accordingly, foreign...
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* 2/16/2021 UPDATE: on 2/16/2021, Ansarallah’s FTO and SDGT designations were removed. As a result, OFAC removed FAQ # 875, FAQ # 876, FAQ # 877, and archived Ansarallah-related GTSR/FTOSR General License 9, GTSR/FTOSR General License 10, GTSR/FTOSR General License 11, GTSR/FTOSR General License 12 and GTSR/FTOSR General License 13. See https://web.archive.org/web/20221004154552/https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210216.
1) See FAQ # 875 for the “General Background Comment Common to the 1/19/2020 FAQs and General Licenses Related to the Designation of Ansarallah as an FTO/SDGT.”
*FAQ updated on Jan. 25, 2020, to account for the issuance of