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870. On December 14, 2020, OFAC added a person to the Non-SDN Menu-Based Sanctions List (NS-MBS List) and indicated that the person was subject to the loan and credit-related sanction described in section 235(a)(3) of the Countering America’s Adversaries Through Sanctions Act (CAATSA).  What does this sanction prohibit?


With respect to a person on the NS-MBS List subject to section 235(a)(3) of CAATSA, as implemented by section 1(a)(i) of Executive Order (E.O.) 13849, U.S. financial institutions are prohibited from making loans or providing credits to the identified person totaling more than $10,000,000 in any 12-month period, unless the person is engaged in activities to relieve human suffering and the loans or credits are provided for such activities.  This is not a blocking sanction, but rather a limit on the total amount of loans or credits that can be provided to the identified person within the specified time period by a U.S. financial institution, excluding loans or credit provided to such identified person for activities to relieve human suffering.  

Each U.S. financial institution must limit its provision of loans or credits to the identified person to $10,000,000 in any 12-month period, regardless of whether part or all the loans or credits in question has been repaid during the period.  This sanction is not a limit on the total loans or credits from all United States financial institutions collectively in the specific time period, but rather an institution-by-institution limit.

Date Released
January 5, 2021