OFAC FAQ (Current) # 545 - Section 228 (CAATSA)

Date issued: Jan. 05 2021

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TURBOFAC Commentary (1098 words)


1) This FAQ interprets elements of the secondary sanctions in SSIDES Sec. 10 (as amended by Sec. 228 of CAATSA) that, as of 1/2021, do not appear in any other secondary sanctions authority. Unlike the Iranian secondary sanctions analogues (CISADA and NDAA), these statutory provisions have not yet been implemented in executive orders or the Code of Federal Regulations, but as written they need not be implemented by the Executive in order to be active.


With respect to the term "knowingly," that knowledge qualifier is defined consistent with the definition of that term used by OFAC in all other secondary sanctions contexts. See General Note on the terms "knowingly," "should have known" and "reason to know" in the Primary Sanctions, Secondary Sanctions and Derivative Designation...