65 … OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not have knowledge that it was engaging in a transaction that was prohibited under sanctions laws and… Read more
102 … The best and most reliable approach for issuing policies with global risk coverage without violating U.S. sanctions law is to include a clause ensuring there is no coverage for risks that violate U.S. sanctions law. The exact wording of such clauses may vary depending on the type of policy (e… Read more
103 … OFAC recognizes that U.S. insurers and reinsurers often compete in international markets where non-U.S. insurers are willing and able to issue global insurance policies without an exclusion that applies to U.S. sanctions, or where such clauses may be prohibited under local law. In cases where… Read more
14 … Great care should be taken when placing reliance on such materials to ensure that the transactions in question fully conform to the letter and spirit of the published materials and that the materials have not been superseded. … Can I regard previously issued and published opinion letters,… Read more
15 … Yes. OFAC, therefore, strongly encourages parties to exercise due diligence when their business activities may touch on an OFAC-administered program and to contact OFAC if they have any questions about their transactions. … Can OFAC change its previously stated, non-published interpretation or… Read more
468 … If you have questions about the authenticity of an OFAC-issued document that is not publicly posted on OFAC’s website, you may contact OFAC and reference the specific case ID or FAC number that is included on the document. For specific licenses, please visit OFAC’s Licensing Portal and select… Read more
469 … No. OFAC does not issue non-inclusion certificates to show an entity or individual is not listed on one of OFAC’s sanctions lists, nor does OFAC publish a “safe list.” For questions regarding whether a specific entity or individual may be a positive match to an entry on one of OFAC’s… Read more
91 … OFAC publishes lists of individuals and entities that are subject to OFAC-administered sanctions. One such list is known as the List of Specially Designated Nationals and Blocked Persons List, or "SDN List," which is available on OFAC’s website . Property and interests in property of the… Read more
126 … A package may be blocked or rejected for multiple reasons. U.S. persons, including shipping companies, are required to "block" packages in which a person blocked by OFAC-administered sanctions has an interest. When a package is required to be "blocked" due to sanctions, the shipper must… Read more
74 … A license is an authorization from OFAC to engage in a transaction that otherwise would be prohibited. There are two types of licenses: general licenses and specific licenses. A general license authorizes a particular type of transaction for a class of persons without the need to apply for a… Read more