On January 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the publication of two new FAQs related to the Countering America’s Adversaries Through Sanctions Act (CAATSA). FAQ 869 states that entities owned 50 percent or more by a person subject to the non-blocking menu-based sanctions in Section 235(a) of CAATSA are not subject to the same non-blocking sanctions. FAQ 870 details the prohibitions of the loan and credit-related sanction described in Section 235(a)(3) of CAATSA. Additionally, OFAC amended FAQ 545 and 546.
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