OFAC Descriptions of 17 Huawei-related VSDs and Dispositions

Date issued: Sep. 10 2026

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TURBOFAC Commentary (92 words)

Notes:

1) Notable description of OFAC’s enforcement practices in general, and in particular as it relates to when OFAC issues no action letters. The spreadsheet prepared by OFAC indicates that c issues no action letters to U.S. financial institutions in cases where there were violations by the financial institutions (on a strict liability basis), but “the original payment messages did not contain references to any sanctioned party or jurisdiction, the payments were not flagged for review” (i.e. the institutions had no reason to know of the facts giving rise to the violations).