OFAC FAQ (Current) # 993 - Afghanistan-Related Sanctions

Date issued: Feb. 25 2022

Last substantive commentary amendment:
Dec. 08 2023

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TURBOFAC Commentary (155 words)

Notes:

1) Compare FAQ # 840. This FAQ accords with OFACs across-the-board policy on "routine interactions" with non-blocked entities headed by blocked persons. FAQ # 840 uses the phrase "SDN is an official or otherwise exercises control". Here it's " has a leadership role in". Contrast Case No. COTED-6-1.

Note the distinction between OFAC's use of the terms "prohibited" and "authorized". The "routine interactions" are outside the scope of the blocking prohibition altogether. The signing the contract with the blocked person " in their official capacity on behalf of the governing institution" is authorized pursuant to GL 20 (and possibly GLs 14-19 as well but the issue is largely moot). But that activity would be prohibited but for the GL.

2) Compare FAQ # 1145 (similar but specifies that...