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The devil is in the details

Economic sanctions programs are not. in general, a total prohibition in business dealings. To know which things are permissible, you need to go beyond the list to whatever descriptive guidance is given by the specific regulator.

OFAC, in particular, puts voluminous information on its website for each program. In addition to a basic information flyer (usually available in PDF and Text formats), there are also additional documents for each General License granted for the program. General Licenses describe classes of business transactions that are permitted and represent an exception to the prohibitions of the program.

I’ve just added links to all of OFAC’s sanctions flyers (Lebanon and Syria don’t have current documents available) on the Regulatory Links page. Over time, I will add links to the General Licenses, as well as to the equivalent documents issued by other regulators as I encounter them.

Categories: OFAC Updates

eric9to5

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