Policy Alert on Disrupting Irregular Migration: Best Practices in Response to Recent Developments in the Aviation Sector

Date issued: May. 15 2024

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TURBOFAC Commentary (148 words)

Note:

1) This “advisory” is light on OFAC-related content. To the extent it breaks any sort of news, it is the “statement of sanctioning policy” in which OFAC signals its intent to use its Global Magnitsky authorities to target persons “involved in corruption or serious human rights abuses related to human smuggling and other irregular migration.”

2) For comments on the statement concerning "strict liability," see General Note on the Terms "Knowingly," "Should Have Known" And "Reason to Know" In the Primary Sanctions, Secondary Sanctions and Derivative Designation Contexts (System Ed. Note). ("OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not know or have reason to know that it was engaging in a transaction that was prohibited under sanctions...