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Financial Services Law Insights and Observations

OFAC Authorizes Certain Transactions and Activities to Liquidate Honduras-Based Bank, Replaces Previously Issued General License

Anti-Money Laundering OFAC

Federal Issues

On December 8, OFAC announced that it issued a revised General License replacing a previously issued license to a Honduras-based bank, which OFAC designated as a Specially Designated Narcotics Trafficker. The General License authorizes certain transactions and activities to assist with the liquidation and winding down of the bank. The revised General License permits liquidation-related transactions and activities that are otherwise prohibited by the Foreign Narcotics Kingpin Sanctions Regulations through 12:01 a.m. on June 12, 2016, with the following exceptions: (i) the unblocking of any blocked property pursuant the Foreign Narcotics Kingpin Sanctions Regulations; or (ii) transactions or dealings that are limited by Executive Order or are with another individual or entity on OFAC’s List of Specially Designated Nationals or Blocked Persons. U.S. persons involved in the bank’s liquidation process must file a report with OFAC’s Licensing Division to include the parties involved, and the type, scope, and dates of the activities conducted.