31 CFR § 560.502 - Effect of license or authorization.

Date issued: Oct. 22 2012

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TURBOFAC Commentary (950 words)

1) Notes Common to Subsections (a)-(c) of the 500-level "Effect of license or authorization" Provision.

Subsections (a) through (c) of this provision are, with certain non-substantive exceptions, common to most sanctions regulations. Subsection (a) deals with "retroactive licensing," which, depending on the situation, can be within OFAC's authority, but is, as noted, not the default. Subsection (b) is a general restatement of the common 5XX.101 provision (Relation of this part to other laws and regulations) but note that a significant portion of OFAC's guidance that is designed to have cross-programmatic application does not specifically refer to every part of the CFR to which it applies. By the same token, subsection (c) cautions to read license and authorizations restrictively, which is a good rule of thumb, but OFAC frequently offers guidance interpreting authorization provisions more broadly than the plain text might otherwise...