OFAC FAQ (Removed) # 471 - General Licenses Issued Authorizing Certain Activities Pertaining to Panama

Date issued: Jan. 05 2017

TURBOFAC Commentary (126 words)

Notes:

1) FAQ Removed with the expiry of the associated GL (FNKSR - General License 3).

2) There is a list of activities included within the scope of an ordinary wind-down GL. "Information dissemination via social media and other web applications" stands out as unique to this GL, perhaps because the FNKSR contain no "information and informational materials" exemption, as do the CACR and IEEPA-based sanctions programs. The paid-for dissemination of even pre-existing and fully created information is a service prohibited by 598.203 that would be exempt in the context of the ordinary IEEPA-based set of sanctions regulations.

3) See generally Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.