​Guidance on the Provision of Certain Services Relating to the Requirements of U.S. Sanctions Laws (Compliance Services Guidance)

Date issued: Jan. 12 2017

Last substantive commentary amendment:
Sep. 25 2023

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TURBOFAC Commentary (2261 words)

Notes:

1) Related FAQs

See FAQ # 495, FAQ # 496, FAQ # 497, FAQ # 498 and FAQ # 499, and comments thereto, all of which were released on the same day as this guidance.

2) Cross-programmatic Nature


This guidance, like the Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked, applies cross-programmatically to all of "31 C.F.R. chapter V." This presumably includes OFAC-administered prohibitions imposed by executive orders that are pending implementation in the CFR, and are therefore technically not prohibited "pursuant to any part of 31 C.F.R. chapter V."

3) Confirmation of the Cross-Programmatic “Implicit Facilitation Prohibition”


Although this has been presumed to be the case for some time, the guidance appears to be the first...