Following the Kovay Gardens designations, OFAC published related counter‑narcotics and cyber‑fraud materials including Counter Terrorism General License 34 to authorize wind‑down activity. The guidance clarifies immediate compliance, permitted wind‑down transactions, and steps for U.S. persons and financial institutions to respond.

Coinciding with the Kovay Gardens sanctions, OFAC released a sanctions‑program page and issued a general license (identified in press materials as Counter Terrorism General License 34) to authorize certain limited wind‑down activities and provide compliance relief for U.S. persons and institutions handling affected transactions. The guidance outlines permitted transactions to facilitate orderly termination of contracts, processing of certain refunds or returns where allowed, and the targeted timeframe in which designated counterparties may conduct narrowly defined wind‑down operations without violating blocking sanctions. OFAC also published explanatory materials detailing the CJNG timeshare‑fraud network, flagged potential indicators of illicit activity for financial institutions, and provided contact points for reporting suspected dealings and victim assistance. The package is intended to limit collateral disruption to legitimate customers while preserving Treasury’s ability to freeze and block designated assets and to assist banks and other intermediaries in implementing immediate compliance measures.