OFAC FAQ (Removed) # 807 - Iran-related FAQ (EO 13846)

Date issued: Dec. 19 2019

Last substantive commentary amendment:
Jun. 15 2023

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TURBOFAC Commentary (1057 words)


*FAQ Removed at some point in 2020, presumably due to the expiry of Iran GL K.

1) *Note Common to FAQ # 807, FAQ # 835, FAQ # 841, FAQ # 883, FAQ # 1102 and FAQ # 1112

FAQ # 835, FAQ # 841, FAQ # 883, FAQ # 1102 and FAQ # 1112 all stand for the notable proposition as it relates to U.S. person facilitation of other involvement in underlying transactions of non-U.S. persons that are described by a general license, but not within the scope of OFAC's jurisdiction to begin with. More specifically, the FAQs all interpret standard wind down GLs that authorize "all transactions prohibited by the [sanctions] that are ordinarily incident and necessary to the wind down of any transaction involving [certain blocked...