Treasury Targets Vessels Delivering Oil Derivatives to the Houthis (Press Release)

Date issued: Apr. 28 2024

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TURBOFAC Commentary (373 words)

Notes

1) See Treasury Targets Vessels Delivering Oil Derivatives to the Houthis (Press Release) (entities designated for acting outside scope of wind down GL). This appears to be the first time ever that OFAC has designated an entity while explicitly noting that the conduct resulting the designation qualified for a recently expired wind down GL (“Maisan finished discharging its cargo and departed Ras Isa on April 8, four days after the expiration of OFAC’s GL 25A”). Designations for transactions that do not qualify for a wind down GL but would have qualified for wind down GLs for U.S. persons when such GLs were still valid are extremely rare, and here OFAC explicitly calls out the fact that an otherwise applicable wind down GL was valid just four days prior to the sanctionable conduct taking place. The unusual step taking in this...