OFAC Issues New FAQ for Belarus, Ukraine/Russia, Venezuela Sanctions
The Office of Foreign Assets Control issued a new frequently asked question to address how certain “loans, contracts, or other agreements” are treated under its Belarus, Ukraine/Russia and Venezuela sanctions programs. The FAQ, issued Jan. 7, outlines how OFAC views…
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
modifications to “pre-existing loans, contracts, or other agreements to replace London Interbank Offered Rate (LIBOR) as the reference rate.” The agency said any loans or contracts that use LIBOR as a reference rate and are “modified to replace such benchmark reference rate” won’t be treated as new debt for OFAC sanctions purposes, “so long as no other material terms of the loan, contract, or agreement are modified.”