> Does OFAC have the power to say "we are designating the Hawala system"?
Probably not because "Hawala system" is not an entity that can be defined - it's like banning "cryptocurrencies" in general. OFAC wouldn't be able to do that - because it's not a specific definable entity. Designating a specific hawaladar would be possible for them (though likely not very effective).
It seems to be a mandated requirement, as opposed to some subjective UI decision. The bigger deal is that it may indicate they don't have a good enough process to check/track these federal requirements.
That's a different type of ambiguity. That's ambiguity in the wording. The bureaucrat in question is saying they'll make the next thing illegal straight away, not that they need to go fix their poor wording.
> (c) The prohibitions in subsections (a)–(b) of this section apply [...] notwithstanding any contract entered into or any license or permit granted prior to the effective date of this order.
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