Guidance on Transactions Related to Subsistence or Basic Human Needs for Individuals Designated Under Executive Order 14115, “Imposing Certain Sanctions on Persons Undermining Peace, Security, and Stability in the West Bank.” (March 29, 2024)

Date issued: Mar. 26 2024

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TURBOFAC Commentary (885 words)

Notes:

1) BACKGROUND

As of the date of issuance of this letter, EO 14115 is a standard list-based blocking program not yet implemented in OFAC’s regulations. Of particular note for purposes of this letter, the EO contains the standard derivative designation criterion concerning persons that have been determined “to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person blocked pursuant to [the EO]”. The term “Financial, material, or technological support” is defined extremely broadly in OFAC’s regulations, covering “any property, tangible or intangible, including currency, financial instruments, securities, or any other transmission of value…” The persons blocked as of the date of the issuance of the letter were “individuals and entities associated with actions that undermine peace, security, and stability in the West Bank,” including...