> 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

> 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).