On March 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended General License 1A “Official Business of the United States Government” and General License 2A “Authorizing the Wind Down of Transactions Involving the Nicaraguan National Police” to clarify they were also issued under the Nicaraguan Human Rights and Anticorruption Act of 2018, 50 U.S.C. § 1701 (NHRA). Among other things, the NHRA directs the president to impose sanctions on persons engaging in significant acts of violence, human rights violations, significant corruption and acts that undermine democratic processes or institutions in Nicaragua. OFAC has added the Nicaraguan National Police (NNP) and several other entities and individuals to the SDN List pursuant to this authority.
No substantive changes were made to the previous versions of General License 1 and General License 2, but they were superseded and replaced by General Licenses 1A and 2A, respectively. General License 1A authorizes transactions otherwise prohibited by the Nicaraguan Sanctions Regulations, 31 C.F.R. §§ 582.101-.901 (NSR) that constitute official business of the U.S. government. General License 2A authorizes transactions otherwise prohibited by the NSR that are ordinarily incident and necessary to the wind down of transactions involving the Nicaraguan National Police (NNP) or any entity the NNP owns, directly or indirectly, a 50% or greater interest, including the processing of salary payments from the NNP to its employees, through 12:01 a.m. ET, May 6, 2020.