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Financial Services Law Insights and Observations

OFAC issues new counter terrorism GL and FAQ

Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury OFAC Sanctions OFAC Designations

Financial Crimes

On November 15, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Counter Terrorism General License (GL) 21, “Authorizing Limited Safety and Environmental Transactions Involving Certain Vessels,” which authorizes limited safety and environmental transactions involving certain persons or vessels that are normally prohibited by the Global Terrorism Sanctions Regulations (GTSR) through 12:01 a.m. EST, December 15, 2022. OFAC explained that such transactions are authorized provided payments to a blocked person are made into a blocked account in accordance with the GTSR. A list of unauthorized transactions are also included. OFAC also issued related FAQ 1097 to provide additional clarification on permitted transactions.