list of ofac general licenses

OFAC Licenses: Do You Need a General License or a Specific License? This was recorded before the Paul Carroll no LinkedIn: New OFAC General Licenses for Humanitarian M_;C}EZrB"F${#4eq3mI4\/X|L@# XruR {WzGc d>dx%o%fjn,Vvoy{"i )u (@!%d%@B x@ hHk XD O8xo0]`{mPp}`lC]x'08k07x|AAkFA,"|=>f{nvO~! BIS adds a sentence to the end of new paragraph (a)(1)(iii) under 746.7 to specify that reexports and exports from abroad of foreign-produced items that would have otherwise met all of the terms and conditions of an OFAC general license if the transactions had been subject to OFAC license requirements are exempt from BIS license 0000016880 00000 n 0000004656 00000 n All the courses are of global standards and recognized by competent authorities, thus The Office of Foreign Assets Control (OFAC) within the U.S. Department of Treasury is tasked, in part, with ensuring that money from U.S. persons and entities does not fall into the hands of terrorist groups. e f/`m9 R&14@as@VoE&iF ` p endstream endobj 622 0 obj <>/Filter/FlateDecode/Index[64 516]/Length 40/Size 580/Type/XRef/W[1 1 1]>>stream SUMMARY: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing six general licenses (GLs) issued in the Venezuela Sanctions program: GLs 19, 20, 20A, Director, Office of Foreign Assets Control. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued Guidance on Authorized Transactions Related to Earthquake Relief Efforts in Syria (the Guidance). OFAC also published several new General Licenses and amended several existing General Licenses to authorize activities that would otherwise be prohibited 0000004118 00000 n HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. 0000016950 00000 n The sanctions also highlight the USs use of secondary sanctions to sanction individuals and entities aiding Russias war efforts, assisting with sanctions evasion, and the backfilling of necessary parts, components, and materials. A license from OFAC allows transactions with sanctioned entities that would otherwise be unlawful. Thus, it is important to read the regulations carefully each time you take on a legal representation for or on behalf of a blocked person, as the authorizations for payment, and the reporting requirements with respect to those payments vary from program to program and have been changing as new regulations are issued. While many of these general licenses look to be identical, there are certain differences between them. Interviewee: Yes, there are. Incidentally, there license has no expiration date. That guidance provides additional information on the respective license application requirements for those sanctions programs.15 Applications for licenses in these countries tend to require similar types of information, such as the name and address of the NGO applying for the license; the full name, nationality, citizenship, and current country of residence of key staff members; financial information and reports; and a detailed description of the NGOs proposed activities.16 According to 31 CFR 501.801, license applications must be submitted by mail or courier. How does a person or entity apply for a license? The United States continued to employ sanctions against other countries and entities during the Civil War and throughout World War II, when the Office of Foreign Funds Control, the immediate predecessor to OFAC, was created. 0000027594 00000 n Webin certain types of transactions specified by the license.7 According to OFAC, [a] license is an authorization from OFAC to engage in a transaction that otherwise would be Traditionally, OFAC required payments made under those types of licenses both (general and specific) to be reported to the Licensing Division on a quarterly basis. 0000035570 00000 n As the Founder and Principal of Ferrari & Associates, P.C., Mr. Ferrari represents U.S. and foreign corporations, financial institutions, exporters, insurers, as well as private individuals in trade compliance, regulatory licensing matters, and federal investigations and prosecutions. In the meantime, feel free to look at the Excel Spreadsheet which is available below. 0000001945 00000 n [FR Doc. He frequently represents clients before the United States Department of the Treasurys Office of Foreign Assets Control (OFAC), the United States Department of Commerces Bureau of Industry and Security (BIS), and in federal courts around the country. For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. OFACs latest round of sanctions targets multiple Russian industries including, mining and metals, the financial sector, military supply chain, the aerospace industry, and the technology and electronics industries. Quantum What? tuition and home schooling, secondary and senior secondary level, i.e. If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. For example, specific licenses issued under the Foreign Narcotics Kingpin Sanctions Regulations (FNKSR) for payments related to the provision of legal services to parties blocked under the Foreign Narcotics Kingpin Designation Act (Kingpin Act) now only require annual reports to made on an annual basis. Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials, replaces and supersedes GL 6B (see previous blog post here), On December 30, 2022, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) issued Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (Petroleum Products Guidance). Indeed, the only conditions 31 C.F.R. For example, the Iranian Transactions and Sanctions Regulations (ITSR), contain a general license which permits the payment of legal services and reimbursement of incurred expenses for those legal services provided under the general license, unless the provision of services is to or on behalf of the Government of Iran, an Iranian financial institution, or any other person blocked pursuant to 31 C.F.R. provided in . The changes also amend some General Licenses already in effect, including: While this is encouraging, CAF America notes that the updates allow specific activities in each country, with particular INGOs added as allowable partners. WebOffice of Foreign Assets Control 31 CFR Part 591 Publication of Venezuela Sanctions Regulations Web General Licenses 36, 36A, 37, (OFAC) is publishing five general I was already a teacher by profession and I was searching for some B.Ed. Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Quantum What? . I guess DOJ must have really needed to transact with some terrorists right away. Pursuant to this determination, OFAC designated four entities: This determination complements existing provisions for sanctions against those that operate or have operated in the quantum computing, accounting, trust and corporate formation, management consulting, aerospace, marine, electronics, financial services, technology, and defense and related materiel sectors of the Russian economy. General License 13D authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase WebWhen expanded it provides a list of search options that will switch the search inputs to match the current selection. 13382. Build a Morning News Brief: Easy, No Clutter, Free! On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities operating in Russia and against those assisting with Russias war efforts in Ukraine. Dismiss. Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. To embed, copy and paste the code into your website or blog: Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: [HOT] Read Latest COVID-19 Guidance, All Aspects [SCHEDULE] Upcoming COVID-19 Webinars & Online Programs, [GUIDANCE] COVID-19 and Force Majeure Considerations, [GUIDANCE] COVID-19 and Employer Liability Issues. December 23, 2021 Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. are blocked . The database also reveals a lot of interesting information. Reporting requirements with respect to general or specific licenses for payment of professional fees from unblocked sources related to the provision of generally authorized legal services to blocked persons have also evolved over recent years. For additional information regarding the scope of the Russian sanctions and the General Licenses thereto, see OFACs FAQ These General Licenses go far to allow for more funding to aid the Afghan people, but donors should be careful to assess the risks of giving to Afghanistan even with these new permissions. 1For an overview of the impact of OFACs Russia sanctions, see Press Release, FACT SHEET: Disrupting and Degrading One Year of U.S. Sanctions on Russia and Its Enablers, U.S. DEPT. 0000021398 00000 n This authorization comes in the form of a license, which allows an individual or entity to engage in certain types of transactions specified by the license.7According to OFAC, [a] license is an authorization from OFAC to engage in a transaction that otherwise would be prohibited.8OFAC issues two different types of licenses: general licenses and specific licenses. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. Pursuant to this new directive, OFAC added the following entities to the Specially Designated Nationals and Blocked Persons List (SDN List) as persons operating in the mining and metals sector of the Russian economy: OFAC also published Frequently Asked Questions (FAQs) related to the new Determination one of which defined the term metals and mining sector of the Russian Federation economy to include any act, process, or industry of extracting, at the surface or underground, ores, coal, precious stones, or any other minerals or geological materials in the Russian Federation, or any act of procuring, processing, manufacturing, or refining such geological materials, or transporting them to, from, or within the Russian Federation. Examples of comprehensive sanctions programs include Burma (Myanmar), Cuba, Iran, Sudan, and Syria.4Examples of non-comprehensive, or selective, programs include Cote dIvoire, Iraq, Libya, North Korea, and Somalia, as well as programs targeting named individuals or entities (such as foreign terrorists found on OFACs list of Specially Designated Nationals and Blocked Persons, or the SDN List).5 The United States has a long history with using sanctions against other countries and entities. As the Founder and Principal of Ferrari & Associates, P.C., Mr. Ferrari represents U.S. and foreign corporations, financial institutions, exporters, insurers, as well as private individuals in trade compliance, regulatory licensing matters, and federal investigations and prosecutions. 0000004586 00000 n Multiple Udodov companies were also added to the SDN List including, Udodovs Moscow-based management consulting firm, Limited Liability Company Aforra Management and several others. hbb2g`b``3 1` V endstream endobj 581 0 obj <>/Metadata 62 0 R/Pages 61 0 R/StructTreeRoot 64 0 R/Type/Catalog/ViewerPreferences<>>> endobj 582 0 obj <>/Font<>/ProcSet[/PDF/Text]>>/Rotate 0/StructParents 1/TrimBox[0.0 0.0 612.0 792.0]/Type/Page>> endobj 583 0 obj <> endobj 584 0 obj <> endobj 585 0 obj <>stream For instance, counterterrorism sanctions are authorized by diverse legal authorities, including Executive Order 13224, the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), and various sections of the Code of Federal Regulations (CFR).3. of International Grantmaking, The How to? of Domestic Grantmaking. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Rather, OFAC states that it will reconsider its licensing decisions only for good cause, defined as situations where the applicant can demonstrate changed circumstances or submit additional relevant information not previously made available to OFAC.26 The only challenge a person or entity could make to OFACs denial of a license would be through the judicial process: here, the party challenging the decision would have to prove that OFAC acted arbitrarily and capriciously in denying the license application. 0000036189 00000 n 202304360 Filed Two of the more interesting license applications were put in by U.S. government agencies. Unlike general licenses, specific licenses cannot be utilized by other parties, though it may be possible to obtain a specific license that is similar to an existing one issued to another SDN, creditor or other party. develop their business skills and accelerate their career program. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. Director, Office of Foreign Assets Control. OFAC has the authority both to enforce these laws, by freezing the assets of any U.S. group or individual who violates them, and to provide exceptions to these laws through licenses. 0000021700 00000 n For example, 31 CFR 595.305 defines a general license as any license or authorization the terms of which are set forth in this part. Specific licenses, defined in 31 CFR 595.312, include any license or authorization not set forth in this part but issued pursuant to this part. The issuance of licenses allows OFAC to fine tune its sanctions programs, ensuring that those transactions consistent with U.S. policy are permitted.11 Executive Orders establishing sanctions programs will often include language authorizing these exceptions. 13224., Along with this recent issuance, OFAC has published. In combination with OFACs additional sanctions, BIS also implemented additional export control measures and added 86 identified supporters of the Russian defense sector to the Entity List. [FR Doc. Sanctions Targeting Russias Military Supply Chains. 14024) which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy. Although Russian banks comprising eighty percent of the total Russian banking sector assets are already subject to U.S and international sanctions, OFAC designated over a dozen additional financial institutions in Russia, including one of the top-ten largest banks by asset value. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. Dismiss. General License 23 does not authorize importation of petroleum or petroleum products of, On January 17, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) amended (i) certain Russia-related General Licenses (GLs) and (ii) four Russia-related Frequently Asked Questions (FAQs). Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize four types of broad-ranging activities supporting much-needed humanitarian aid and assistance. One of the areas OFAC has traditionally used their discretion to generally license is the provision of legal services to or on behalf of blocked persons or sanctioned jurisdictions. 13382. I Individuals or entities that violate OFAC regulations may incur civil or criminal penalties, including fines of $50,000 to $10 million, as well as ten to thirty years imprisonment for any willful violations.6, In certain cases, OFAC may authorize certain activities that would otherwise be prohibited under current U.S. sanctions. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. liat takes notes on the behaviors, is jennifer thigpen related to lynne thigpen, social anhedonia test, Broad-Sweeping exemptions to sanctions on any person operating in the meantime, free. Interesting information while many of these general Licenses look to be identical there! Need a general license or a Specific license Filed Two of the more interesting license applications were put in U.S.... With Highly-Qualified Lawyers Using the Most Efficient Practices allows transactions with sanctioned entities that would otherwise be.... 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