Can OFAC change its previously stated, non-published interpretation or opinion without first giving public notice?

OFAC's answer

Yes. OFAC, therefore, strongly encourages parties to exercise due diligence when their business activities may touch on an [OFAC-administered program](https://ofac.treasury.gov/sanctions-programs-and-country-information)and to [contact OFAC](https://ofac.treasury.gov/contact-ofac) if they have any questions about their transactions.