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…
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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.”