Counter Terrorism General License 28A - Authorizing Transactions for Third-Country Diplomatic and Consular Missions Involving Ansarallah (March 05, 2025)

Date issued: Mar. 05 2025

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TURBOFAC Commentary (137 words)

Notes:

[Update - on March 4, 2025, the State Department (re)designated Ansarallah as a FTO (see FAQ # 1219), causing OFAC to reissue this GL and others to add an authorization for transactions otherwise prohibited by the FTOSR. No other substantive chances were made to this GL].

1) Provision type common to all programs involving blocked governments, though with significant variations across programs. Compare 560.541 (ITSR), 542.517 (SySR), 510.515 (CACR), 510.515 (NKSR) and Venezuela General License 23. Provisions of this type have been subject to very little formal guidance.

2) With respect to the “financial transfers” carveout that is standard in this and other Jan-Feb 2024 Ansarallah-related GLs, see section 6(v) Temporary Note Concerning the Status...