31 C.F.R. § 536.402

Effect of amendment

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Any amendment, modification, or revocation of any section of this part or of any order, regulation, ruling, instruction, or license issued by or under the direction of the Director of the Office of Foreign Assets Control shall not, unless otherwise specifically provided, be deemed to affect any act done or omitted to be done, or any civil or criminal suit or proceeding commenced or pending prior to such amendment, modification, or revocation. All penalties, forfeitures, and liabilities under any such order, regulation, ruling, instruction, or license shall continue and may be enforced as if such amendment, modification, or revocation had not been made.

Notes of Decisions
Cited in 3 cases (1 in the last 5 years), 2014–2026 · leading case: Keith Stansell v. Revolutionary Armed Forces of Columbia, (FARC), 771 F.3d 713 (11th Cir. 2014).
Keith Stansell v. Revolutionary Armed Forces of Columbia, (FARC), 771 F.3d 713 (11th Cir. 2014). · cites it 3× “31 C.F.R. § 536.402 (emphasis added). Claimants contend that the district court incorrectly interpreted this regulation to prevent giving retroactive effect to OFAC de-listing.”
Miriam Sutherlin v. Wells Fargo Bank N.A. (11th Cir. 2019). “3d at 733 ; see 31 C.F.R. § 536.402 (stating that any revocation of an order or ruling issued by OFAC “shall not” affect “any civil .”
Meudy Albán Osio in her Pers. capacity & in her capacity as the Pers. Rep. of the Est. of Fernando Alberto Albán, et al. v. Nicolas Maduro Moros, et al. (S.D. Fla. 2026). “UNITED STATES DIST JUDGE 'Tn the Report, Judge Torres cites to 31 C.F.R. § 536.402 which addresses amendments to OFAC orders in the context of Narcotics Trafficking Sanctions Regulations.”
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