The NDAA Includes Another Reason For United States Financial Institutions To Avoid State Sponsors Of Terrorism (Cuba On The List): More Reporting Means More Costs And More Scrutiny.

On 23 December 2022, Joseph Biden, President of the United States, signed into law the National Defense Authorization Act (NDAA) for Fiscal Year 2023 (P.L. 117-263) which includes provisions relating to United States export controls and sanctions. 

Banking Transparency for Sanctioned Persons Act of 2022- Section 5706 of the NDAA incorporates the Banking Transparency for Sanctioned Persons Act, which requires the United States Secretary of the Treasury, not later than one year after enactment, to issue an annual report detailing specific licenses issued by the United States Department of the Treasury in the preceding year that authorize United States financial institutions to provide financial services to the government of a country listed by the United States Department of State as “State Sponsor of Terrorism”, or persons sanctioned by the Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury under Global Magnitsky Act sanctions.  These licenses typically authorize the facilitation of transactions including humanitarian (medical equipment, medical instruments, medical supplies, pharmaceuticals), agricultural commodities and food products, and farming supplies.