OFAC FAQ (Current) # 870

Date issued: Jan. 05 2021

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TURBOFAC Commentary (593 words)

Notes:

1) The Iran Sanctions Act equivalent of the CAATSA “loans or credits” sanction has been imposed in the past, including against persons that were subject to that sanction and no full blocking sanctions. We are, however, unaware of any guidance that meaningfully interprets the scope of the sanction, either in the CAATSA context or the ISA context, apart from this FAQ.

The text prohibits:

“any United States financial institution from making loans or providing credits to the sanctioned person totaling more than $10,000,000 in any 12-month period, unless the person is engaged in activities to relieve human suffering and the loans or credits are provided for such activities.”

Inasmuch as this FAQ provides guidance on the scope of the prohibition, it is notable for the warning that what matters...