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Can OFAC change its previously stated, non-published interpretation or opinion without first giving public notice?
Yes. OFAC, therefore, strongly encourages parties to exercise due diligence when their business activities may touch on an OFAC-administered program and to contact OFAC if they have any questions about their transactions.
Office of Foreign Assets Control (OFAC), U.S. Treasury Department http://www.treas.gov/offices/enforcement/ofac/
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