OFAC针对也门胡赛武装签发新的通用许可证和FAQ

文章系本公众号独家首发，未经授权不得转载、摘编

美国时间1月25日，美国财政部海外资产控制办公室（The Office of Foreign Assets Control of the US Department of the Treasury，OFAC）在官网发布针对也门胡赛武装（Ansarallah）签发的通用许可证General License No.13，该许可证许可的范围比1月19日签发的仅许可基于人道主义的交易范围更加广泛。

主要内容

Authorizing Transactions Involving Ansarallah

(a) Except as provided in paragraph (b) of this general license, all transactions and activities involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, prohibited by the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, are authorized through 12:01 a.m. eastern standard time, February 26, 2021.

(b) This general license does not authorize:

• The unblocking of any funds in accounts of the blocked persons identified in paragraph (a) of this general license that were blocked as of 12:01 a.m. eastern standard time, January 25, 2021.

• Any transactions or activities otherwise prohibited by the GTSR, the FTOSR, or any other part of 31 C.F.R. chapter V, or E.O. 13224, as amended, or any transactions or activities with any blocked persons other than the blocked persons identified in paragraph (a) of this general license.

FAQ

Q: Do non-U.S. persons risk exposure to sanctions under E.O. 13224, as amended, for engaging in transactions involving Ansarallah, or any entity in which Ansarallah owns a 50 percent or greater interest, that U.S. persons would be authorized to engage in under General Licenses 9, 10, 11, 12, and 13? 

A: Non-U.S. persons may engage in or facilitate transactions involving Ansarallah, or any entity in which Ansarallah owns, directly or indirectly, a 50 percent or greater interest, without exposure to sanctions under E.O. 13224, as amended, if such activity would be authorized under General Licenses (GLs) 9, 10, 11, 12, and 13 if engaged in by a U.S. person.  Activity that would be authorized by GLs 9, 10, 11, 12, and 13 if engaged in by a U.S. person would not be considered “significant” for the purposes of a secondary sanctions determination under E.O. 13224, as amended.  

Accordingly, foreign financial institutions do not risk exposure to correspondent and payable-through account sanctions under E.O. 13224, as amended, if they knowingly conduct or facilitate a transaction on behalf of Ansarallah, or any entity in which Ansarallah owns, a 50 percent or greater interest, that would be authorized under GLs 9, 10, 11, 12, and 13 if engaged in by a U.S. person.

General License No.13PDF文件下载

新闻采编：H.ZhY

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