OFAC FAQ (Current) # 176 - NDAA (Section 1245 of the National Defense Authorization Act for Fiscal Year 2012)

Date issued: Feb. 14 2012

TURBOFAC Commentary (69 words)

Notes:

1) "Financial transaction" was defined at 561.325 to mean "any transfer of value involving a financial institution." This definition was implemented subsequent to the posting of the FAQ. It is fairly obvious that oil-as-debt payment would fall within the scope of the IFSR definition of "financial transaction." Examples of "financial transactions" not appearing in the regulations are given at FAQ 178, FAQ 176 and FAQ 174.