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OFAC Authorizes Humanitarian Aid to Afghanistan

OFAC issued two general licenses authorizing certain Afghanistan humanitarian aid and activities involving the Taliban or the Haqqani Network. The licenses authorize transactions otherwise prohibited by the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR); the Foreign Terrorist Organization Sanctions Regulations, 31 C.F.R. part 597 (FTOSR); or, Executive Order 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism,” as amended (EO 13224).

U.S. Targets Chinese Belt & Road Project With Global Magnitsky Sanctions

The Treasury Department’s announcement of the sanctions speaks to the foreign policy and geostrategic significance of the UDG sanctions action. The release speaks of China’s “malign” investment in Cambodia, its use of the UDG projects in Cambodia to “advance ambitions to project power globally,” “disproportionality benefit” itself through BRI projects, and concerns that the Dara Kakor project “could be converted to “host military assets.” The Treasury Department’s language echoes U.S. concerns about the BRI and other Chinese international project financing activities, including that China engages in “debt trap” financing.

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