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Nicaragua-related Sanctions

827. What does Nicaragua-related General License (GL) 2 authorize with respect to the Nicaraguan National Police?

GL 2 authorizes the wind down of transactions involving the Nicaraguan National Police (NNP), including the processing of salary payments from the NNP to its employees, so long as no other blocked persons are involved in the transaction, through 12:01 a.m. eastern daylight time, May 6, 2020. This authorization also covers wind down transactions involving any entity in which NNP owns, directly or indirectly, a 50 percent or greater interest. 

OFAC’s designation of the NNP is directed at the NNP as an institution for the violent abuses carried out against the people of Nicaragua. The blocking sanctions apply to the NNP, as well as to the three named NNP commissioners who were designated on the same day, and not to individual, non-designated NNP police officers

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1069. What does Nicaragua General License (GL) 3 authorize?

Nicaragua GL 3authorizes U.S. persons to engage in transactions prohibited by the Nicaragua Sanctions Regulations, 31 CFR part 582 (the NSR), that are ordinarily incident and necessary to the wind down of transactions involving Empresa Nicaraguense de Minas (ENIMINAS), or any entity in which ENIMINAS owns, directly or indirectly, a 50 percent or greater interest (collectively, “Blocked ENIMINAS Entities”), through 12:01 a.m. eastern daylight time, July 18, 2022, provided that any payment to a blocked person must be made into a blocked account in accordance with the NSR.

After the expiration of this authorization, unless exempt or authorized by the Office of Foreign Assets Control, U.S. persons will be prohibited from engaging in transactions with the Blocked ENIMINAS Entities and must block such entities’ property or interests in property that are in, or thereafter come within, the United States, or the possession or control of a U.S. person.

Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under the NSR for engaging in transactions with blocked persons, where those transactions would not require a specific license if engaged in by a U.S. person. 

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