OFAC FAQ (Current) # 867

Date issued: Dec. 22 2020

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (166 words)

Notes:

1) This is the first FAQ in which OFAC confirms that its generally applicable policy as it relates to secondary sanctions—i.e. of not sanctioning non-U.S. persons for activities in which U.S. persons could engage directly—also applies to the secondary sanctions provisions of the Sec. 7401 et seq. of the FY 2020 NDAA (“Caesar Syria Civilian Protection Act of 2019”). Compare FAQ # 545. Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note)

Otherwise, the FAQ does not provide much in the way of anything that could be characterized as "interpretive guidance."

2) It is not spelled out in the regulations, but OFAC confirms that the CBoS can be involved in the processing of transactions...