OFAC FAQ (Removed) # 868

Date issued: Dec. 22 2020

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (912 words)

Notes:

*The version of 542.516 in force as of the time of the issuance of the FAQ can be found at https://www.govinfo.gov/content/pkg/CFR-2020-title31-vol3/xml/CFR-2020-title31-vol3-part542.xml#seqnum542.516. Note that the below was drafted prior to the November, 2021 revisions to 541.516.

Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note).

________

1) THE RELATIONSHIP BETWEEN 542.516 AND THE HUMANITARIAN WAIVER AT SEC. 7432(c) OF THE CAESAR ACT

Read in conjunction with FAQ # 867. Polymedics LLC and Letia Company are two entities that were placed on the SDN list on 12-23-2020. The activities in which those entities are engaged presumably relate in some way to humanitarian-related transactions, otherwise OFAC would not have singled them out in connection with the discussion of 542.516 and humanitarian-related...