The Office of Foreign Asset Control recently announced an initiative to update its list of frequently asked questions on sanctions enforcement. The changes are part of a broader modernization effort by the agency.
For the first update, OFAC updated 14 FAQs. Updates include revisions to clarify when non-U.S. persons are subject to certain sanctions prohibitions, “Who must comply with OFAC sanctions?” to provide examples of when non-U.S. persons are subject to sanctions. It also notes that certain programs require foreign persons reexporting certain goods, technology or services from the U.S. to comply with U.S. sanctions, even if no U.S. persons are involved in the reexport.