OFAC FAQ (Current) # 502 - Cyber-related Sanctions

Date issued: Apr. 27 2023

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (137 words)

Notes:

1) The statement that "transactions involving any property subject to U.S. jurisdiction...remain prohibited unless exempt or otherwise authorized by OFAC," without the qualification of "transactions" as being those "by U.S. persons" can be read as an assertion of jurisdiction over re-exports of U.S. origin goods to SDNs subject to the Cyber-related sanctions (and, by implication, all list-based sanctions programs). News that OFAC intended to control re-exports to SDNs in this manner would be broken in a more explicit fashion.

2) This FAQ was amended on March 2, 2021, to account for the issuance of Cyber GL 1 B, which amended Cyber GL 1 A to account for thedesignation of the FSB pursuant to the WMSPSR, and further amended on April 27, 2023, to account for the issuance of Cyber GL 1 C.