Directive 2 - Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions (February 24, 2022)

Date issued: Feb. 24 2022

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TURBOFAC Commentary (255 words)

Notes:

1) Refer to the following Directive 2-related FAQs for further commentary on this unique set of prohibitions: FAQ # 966, FAQ # 967, FAQ # 968, FAQ # 969, FAQ # 970, FAQ # 971, FAQ # 972, FAQ # 973, FAQ # 974, FAQ # 976, FAQ # 980. For comments on the CAPTA portion of the Directive, see generally General Note on Provisions Containing Secondary/"CAPTA" Sanctions Applicable to Foreign Financial Institutions. This is only the second time that "CAPTA" restrictions have been imposed by OFAC (compare Secondary Sanctions Enforcement Announcement - Kunlun Bank (China) and Elaf Bank in (Iraq)).

2) The second portion of the prohibition ("the processing of a transaction involving foreign financial...