Guidance
OFAC issued Counter Terrorism General License 13, which authorizes transactions with Ansrallah until February 26th, but doesn’t permit transactions otherwise barred under the various counter-terror regulations, other SDNs, or transactions which involved already-blocked property. And they updated Frequently Asked Question (FAQ) 876 to include references to the new General License. […]
FinCEN and Federal Banking Agencies Issue Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Requirements The Financial Crimes Enforcement Network (FinCEN), jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the […]
Today, on January 19th, the U.S. Department of State designated Ansarallah as a Foreign Terrorist Organization under section 219 of the Immigration and Nationality Act, as amended, and as a Specially Designated Global Terrorist under Executive Order (E.O.) 13224, as amended and have been added to the Specially Designated Nationals […]
So, as announced on the White House website on Thursday (I still have not received an email from OFAC – I just decided to check if it had shown up on the Recent Actions page), there is a new Executive Order that amends Executive Order 13959. It basically makes a […]
Two more Frequently Asked Questions about Communist Chinese Military Companies (note that neither the program, nor the FAQ section includes the word “Communist”, but the OFAC Notice does): 863. Can U.S. persons custody, offer for sale, serve as a transfer agent, and trade in covered securities? Answer For purposes of E.O. 13959, […]
OFAC added FAQs 869 and 870 today relating to CAATSA (Countering America’s Adversaries through Sanctions Act): 869. If a person is subject to non-blocking menu-based sanctions described in section 235(a) of the Countering America’s Adversaries Through Sanctions Act (CAATSA), do the same non-blocking sanctions apply to entities owned 50 percent or […]
862. Does Executive Order (E.O.) 13959 require U.S. persons, including U.S. funds and related market intermediaries and participants, to divest their holdings in publicly traded securities (and securities that are derivative of, or are designed to provide investment exposure to, such securities) of the Communist Chinese military companies identified in the […]
The first guidance issued since the end of the Transition Period, it explains Libya sanctions under the Libya (Sanctions) (EU Exit) Regulations 2020. In addition to a section on your garden-variety asset freezes, there are also sections on “partial asset freezes”, a special section just on the LIA (Libyan Investment […]
This is an exception – this is not a limited time General License being renewed for another time period. Two important changes – first, the GL now authorizes transactions with a broader class of persons (it used to be just people appointed by Guaido): (b) Except as provided in paragraph […]
Yesterday, OFAC published the designations made in Executive Order 13959, and subsequently by the Department of Defense in both PDF and CSV forms. They’ve named this “Non-SDN Communist Chinese Military Companies List”, and have added company aliases (also known as, or A.K.A.), the issuer name of any securities, and any […]
