Appendix A to Part 501—Economic Sanctions Enforcement Guidelines

Date issued: Apr. 09 2021

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TURBOFAC Commentary (654 words)

Notes:


1) Given the scope of these comments as being oriented primarily toward the scope and operation of the sanctions law for the purposes of compliance with them, a full analysis of the entirety of the enforcement guidelines is beyond the scope of this note. Refer generally to FR Notice Addressing Regulated Community Comments re: OFAC Enforcement Guidelines (2009), for OFAC commentary on different aspects of the guidelines.


2) Many of the topics addressed in these guidelines, and OFAC's shifting practices with respect to them, are indirectly addressed further by enforcement actions. The Research System contains several tags designed to assist with a better understanding of how OFAC handles certain enforcement guideline-specific issues. Examples include:


* Voluntary self-disclosure credit (Section I.I).


Search by enforcement actions for which VD credit was given and those for which it was not. Voluntary disclosure credit issues are discussed in, e.g., Civil Enforcement...