OFAC FAQ (Current) # 995 - Afghanistan-Related Sanctions

Date issued: Feb. 25 2022

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TURBOFAC Commentary (220 words)

Notes:

1) FAQ confirms that "involving Afghanistan or governing institutions in Afghanistan" includes state-owned enterprises (i.e. is not limited to governing institutions). Cross reference Executive Order on Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan (EO 14064).

The EO blocks "[a]ll property and interests in property of DAB that are held, as of the date of this order, in the United States by any United States financial institution, including the Federal Reserve Bank of New York, are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in, except as set forth in subsections (b) and (c) of this section."

"[A]s of the date of this order" apparently means as of the actual date of the order, not on or after it.


2) The FAQ...