From:
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To: [ ]
Cc:
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[email protected]
Subject: OFAC guidance
Date: Thursday, September 11, 2025 10:16:32 AM
Hi [ ],
As noted in FAQ 1200, “OFAC does not require U.S. persons to obtain a specific license to initiate legal proceedings against a blocked person. For example, a U.S. attorney, insurer, or other service provider initiating arbitral proceedings against a Specially Designated Global Terrorist does not require a specific license. In most OFAC programs, however, a license would generally be required to enter a settlement agreement with a blocked person, to accept payment from a blocked person, or to enforce an order or award transferring blocked property.” As such, Vitol did not require a specific license from OFAC to initiate proceedings against the blocked persons/property in question.
In addition, OFAC issued General...
[Update/Note - OFAC implemented EO 13902 into the ITSR subsequent to the drafting of the comment below. See 560.211 and comments thereto]
1) BACKGROUND
On April 22, 2025, OFAC designated the vessel TINOS I and certain associated persons, and on May 20, 2025, OFAC issued Iran General License Q, which authorized (among other things) “[t]he sale of the Tinos I, provided the net proceeds of the sale be placed into a blocked interest-bearing account at a U.S. financial institution.” The GL contained an interpretive note specifying that “[t]ransactions authorized by paragraph (a)(5) include: bidding on...