OFAC publishes new FAQs on non-blocking menu-based sanctions

OFAC has published 2 new FAQs (869 and (870) relating to the non-blocking menu-based sanctions introduced under Countering America’s Adversaries Through Sanctions Act (CAATSA), see post. The FAQs clarify that: If a person or entity is subject to the sanctions set out in section 235(a)(1-8) and (10-11) of CAATSA (which does not include addition to the SDN list), the measures …