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Today, OFAC issued the following new Frequently Asked Question for its Iran sanctions program: 816. Is there a wind-down period for Executive Order 13902, “Imposing Sanctions with Respect to Additional Sectors of Iran” (E.O. 13902)? Persons engaged in transactions that could be sanctioned under E.O. 13902 with respect to the construction, mining, […]

December 20, 2019: New Ukraine/Russia-related FAQ

On Friday, OFAC issued the following new Ukraine/Russia-related Frequently-Asked Question: 815. How does the U.S. government plan to implement the wind-down specified in Section 7503(d) of the National Defense Authorization Act for Fiscal Year 2020 (NDAA), also known as the Protecting Europe’s Energy Security Act of 2019?    Upon signature by the […]

OFAC adds and updates Iran listings, issues new FAQs

Today, OFAC added a person: KHEDRI, Abdolhossein (a.k.a. KHEDRI, Abdolhossein Heid; a.k.a. KHEDRI, Abdul Hossein; a.k.a. KHODRI, Abed Al Hsein Heid), Iran; DOB May 1971; POB Bushehr Province, Iran; Additional Sanctions Information – Subject to Secondary Sanctions; Gender Male (individual) [SDGT] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE). […]

November 27, 2019: OFAC updates Iran FAQs

Last Wednesday, OFAC updated Frequently Asked Question (FAQ) #303: 303. Which insurance, reinsurance, or underwriting activities are potentially subject to sanctions under IFCA’s section 1246(a)(1)?  A number of insurance activities are subject to sanctions under IFCA, including knowingly providing insurance, reinsurance, or underwriting services to or for Iranian persons on the SDN […]

Oops… OFAC changes also made to Venezuela FAQs

Sorry about this – about those OFAC changes to the Venezuela program I just posted? Well, OFAC also issued a new Frequently Asked Question (FAQ): 803. What types of activity does General License 35 authorize?  U.S. persons are authorized to engage in certain administrative transactions with the Government of Venezuela that are prohibited […]

October 24, 2019: OFAC amends Venezuela General License 5

On Thursday, OFAC updated General License 5 (now 5A) for the Venezuela program, making the authorization for these transactions regarding the PdVSA 8.5% 2020 bond only effective starting in mid-January. They also amended FAQ 595 to explain: 595. What does Venezuela-related General License 5A authorize? The President issued Executive Order (E.O.) 13835 on May 21, […]