list of ofac general licenses

Those entities include: OFAC also designated OOO Zenit Finance, OOO Zenit Leasing, and OOO Zenit Factoring MSP as SDNs for being owned or controlled by or acting on behalf of Bank Zenit. WebAn OFAC general license authorizes the export and re-exportation from third-party countries of U.S. origin goods from the United States, but only in cases where the transactions are authorized by the Commerce Departments 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. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian With over 12 years of experience in national security law, exports control, and U.S. economic sanctions, he counsels across industry sectors representing parties in a wide range of matters from ensuring compliance to defending against federal prosecutions and pursuing federal appeals. of International Grantmaking (10), The "How to?" This was recorded before the Paul Carroll no LinkedIn: New OFAC General Licenses for Humanitarian While not necessarily indicative of the considerations OFAC may weigh with respect to other types of applicants or sanctions programs, the TCRFSP Program guidance provides some insight into the types of considerations that OFAC and other federal agencies may weigh during the review process. Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H I was already a teacher by profession and I was searching for some B.Ed. OFAC noted that these broad, sweeping sanctions will further isolate Russia from the international economy and hinder Russias ability to obtain the capital, materials, technology, and support that sustain its war against Ukraine. of International Grantmaking (10), The "How to?" Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. 0000001176 00000 n Had a great experience here. 0000021700 00000 n For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, 2023 Saavedra-Goodwin All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters. 0000028369 00000 n 13382. the 10/12 Board 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. 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: For an overview of the impact of OFACs Russia sanctions, FACT SHEET: Disrupting and Degrading One Year of U.S. Sanctions on Russia and Its Enablers. 0000021988 00000 n . Director, Office of Foreign Assets Control. The United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has discretion to both specifically license particular transactions, as well as broadly generally authorizei.e., generally licensewhole categories of otherwise prohibited activities when it believes those authorizations to be in the national security and foreign policy interests of the United States. 0000002092 00000 n On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities 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, OFAC also issued an updated guidance document relating to the price cap policy for Russian crude oil and petroleum, On February 9, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) issued Syria General License 23, Authorizing Transactions Related to Earthquake Relief Efforts in Syria. General License 23 authorizes transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations (SySR) through 12:01 p.m. eastern daylight time, August 8, 2023. Director, Office of Foreign Assets Control. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 2023 Saavedra-Goodwin All Rights Reserved 35, issued on August 5, 2019, authorizes the payment of taxes, fees and import duties as well as the purchase of permits, registrations, certifications and public utility services from the Government of Venezuela. The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that produce carbon fiber and related materials. DATES: GL 36 was The CFR contains important elements of the legal framework for OFACs operations, including licenses. Dated: August 5, 2019. 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. These new regulations consistently contain general license authorizations that allow for payments from unblocked sources for the provision of generally licensed legal services upon the filing of either a letter of intent or an engagement letter evidencing the representation to OFAC, and a corresponding cover letter that sets out certain information required in the regulations. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Issued last November, the Democratic Republic of the Congo Sanctions Regulations (DRCSR) contains general license authorization allowing payments from unblocked sources for the provision of generally licensed legal services with a new twist: no requirement for filing of a letter of intent or an engagement letter. At the time the ITSR was issued, the regulations typically required specific license authorization to allow payments from blocked persons for generally authorized legal services provided to that blocked person. 0000003952 00000 n Due to the complexities involved in the application process, it is advisable for all SDNs, creditors and other license applicants to seek guidance from an OFAC attorney. 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. For instance, OFAC states that it may conduct background investigations of each owner, significant shareholder, director, manager, and other key employee [sic] that will be directly involved in the applicants Cuba-related business.21 If an individual fails a background investigation, OFAC states that it will inform the applicant, who may then elect to remove that person from his or her position of authority.22. General Licenses like these are critical components for ensuring that philanthropists and grantmakers in the United States can give with confidence to high-risk countries facing disaster, crisis, and war. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. General License No. HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p 0000004091 00000 n WebOn August 24, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) has imposed new sanctions, updated the SDN list, and issued new documents: Determination pursuant to 1(a)(i) of Executive Order 14024 and four General Licenses (GLs). Two of the more interesting license applications were put in by U.S. government agencies. The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that, Copyright 2023 Sanctions & Export Controls Update, Canada Further Sanctions Iranian Regime: 12 Individuals Targeted, Sanctions Enforcement Around the G7: Intro to Blog Series and View from the United States, Ukraine introduces three new sets of sanctions against persons contributing to the Russian aggression against Ukraine, Japan announces further sanctions against Russia, Canada Imposes Additional Sanctions Against Russia: 129 Individuals and 63 Entities Targeted, Australia adopts further sanctions against Russia, EU adopts 10th package of sanctions against Russia, US Government Imposes New Sanctions, Export Controls, and Tariffs Targeting Russia and Belarus to Mark One-Year Anniversary, OFAC Issues Russian Petroleum-related Determinations, Updates Guidance on Implementation of the Price Cap Policy, and Amends Related General Licenses, OFAC Issues General License Authorizing Earthquake Relief Efforts in Syria, OFAC Issues Amended Russia-Related General Licenses and Related FAQs, OFAC Publishes Preliminary Guidance on Implementing the Price Cap Policy for Petroleum Products of Russian Origin. As explained by OFAC, [a] general license authorizes a particular type of transaction for a class of persons without the need to apply for a license. For example, General License No. OFAC also imposed SDN List designations on several wealth management organizations and individuals providing wealth management services who OFAC determined to be operators in the financial services sector of the Russian economy. 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. 13224 and contains a general license authorization allowing payments for the provision of generally authorized legal services from unblocked sourcesalso maintains a quarterly reporting requirement. 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. '&eeLuM21usXIeUvbt{K"]T@{PMaL}NHz(2P#C%qs[ e5K,wf!o5HO~S,Ldb;E IKA/?Ndh__h#<3ZP~ +,(($ .0 m endstream endobj 586 0 obj <> endobj 587 0 obj <> endobj 588 0 obj <> endobj 589 0 obj <> endobj 590 0 obj <> endobj 591 0 obj [597 0 R] endobj 592 0 obj <>stream These sanctions programs are designed to enable the United States to accomplish its national security and foreign policy goals.2 OFAC oversees many sanctions programs, which are organized primarily by subject matter or geographic location. The White House also issued a statement stating that beginning March 10, there will be a 200% tariff on Russian aluminum entering the US. 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 . S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! I was in search of an online course; Perfect e Learn To ensure that the new Russia sanctions and debt restrictions do not impose unintended harm on third parties and humanitarian efforts, OFAC issued eight general licenses authorizing certain transactions related to international organizations and entities ( General License 5 ); agricultural and medical commodities and the COVID-19 pandemic HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 8F, "Authorizing Transactions Related to Energy," General License 13D, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024," General License 60, "Authorizing the Wind For example, while the Afghan government is not sanctioned, many officials in the new Afghan regime are on the OFAC Specially Designated Nationals (SDN) list, turning any previous work in Afghanistan into a regulatory minefield. 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 licenses (GLs) issued in the Venezuela Sanctions program: GLs 36, 36A, 37, 38, and 39, each of which was previously made available on OFACs website. Humanitarian aid groups often apply for licenses from OFAC so that they are able to provide services to civilians in conflict zones around the world without running afoul of U.S. sanctions law. 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. By issuing General License J-1, OFAC has started to provide its answer, as this particular 202304360 Filed 3123; 8:45 am] BILLING CODE 4810ALP DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 165 [Docket Number USCG20230008] RIN 1625AA00 Safety 13224., Along with this recent issuance, OFAC has published. 547.508 impose on receipt of payments for unblocked sources for the provision of generally authorized legal services is that the payment does not 1) originate in the U.S.; 2) from any source in the possession or control of a U.S. person; and/or 3) from any other blocked persons. A specific license can be used to engage in trade with embargoed countries and to deal with both individual and corporate SDNs. 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. have discontinued my MBA as I got a sudden job opportunity after Seward & Kissel LLP var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); | Attorney Advertising, Copyright var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); JD Supra, LLC. 0000001755 00000 n On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. 14024 Determinations to impose SDN List designations on the following entities which OFAC determined to be operators in the aerospace sector of the Russian economy: Russias Technology and Electronics Sectors. OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock My childs preference to complete Grade 12 from Perfect E Learn was almost similar to other children. 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. 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. On February 24, 2023, the one-year anniversary of Russias invasion of Ukraine, the Department of the Treasurys Office of Foreign Assets Control (OFAC) announced the imposition of additional sanctions targeting multiple sectors of the Russian economy, with the aim of further diminishing Russias ability to continue its war against Ukraine and to procure the resources to support it.1. Perfect E Learn is committed to impart quality education through online mode of learning the future of education across the globe in an international perspective. 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. OFAC also used pre-existing E.O. Agricultural Commodities, Medicine, and Medical Devices (, Official Activities of Certain International Organizations and Other International Entities (, Certain Transactions in Support of Nongovernmental Organizations Activities in Afghanistan (, See a full factsheet on the Afghanistan General Licenses on the OFAC website, If you want to learn more about General Licenses, how they work, and how to design a grantmaking program that complies with all OFAC restrictions in highly-sanctioned countries, read, Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" Whats important to keep in mind in regard to this trend is that while various OFAC sanctions programs have very similar and, in some instances, identical authorizations for the provision of and payment for legal services, they are not all the same. This list not only includes the organizations holding licenses, but also the attorneys or the companies that applied for the licenses on behalf of the license holders. Are you at risk for a breach of contract. Interviewee: Yes, there are. Individuals or entities that violate OFAC regulations may incur civil or criminal penalties, including fines of $50,000 to $10 million, as well as ten to thirty years imprisonment for any willful violations.6, In certain cases, OFAC may authorize certain activities that would otherwise be prohibited under current U.S. sanctions. at a difficult time for the country of Afghanistan, as it faces the threat of a public health crisis, drought, and economic collapse. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. For a full discussion of the export control and Entity List additions see our separate blog post. No Challenge Is Too Great. This General License, however, does not authorize financial transfers to the Taliban, the Haqqani Network, or to any entity in which the Taliban or Haqqani Network owns 50% or greater interest. xJx MBA is a two year master degree program for students who want to gain the confidence to lead boldly and challenge conventional thinking in the global marketplace. Hj 0 endstream endobj 595 0 obj <>stream For example, while the Afghan government is not sanctioned, many officials in the new Afghan regime are on the, OFAC Specially Designated Nationals (SDN) list. 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, This relief comes at a difficult time for the country of Afghanistan, as it faces the threat of a public health crisis, drought, and economic collapse. , turning any previous work in Afghanistan into a regulatory minefield. WebOffice of Foreign Assets Control U.S. Department of the Treasury Treasury Annex 1500 Pennsylvania Avenue, NW Washington, DC 20220 Attn: Licensing Division It is 0000001945 00000 n 202304360 Filed 3123; 8:45 am] BILLING CODE 4810ALP DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 165 [Docket Number USCG20230008] RIN 1625AA00 Safety Control, Treasury Control ( OFAC ) released General license 20 List additions see separate. The US Office of Foreign Assets Control, Treasury OFACs operations, Russian... 2 ), the `` How to? legal framework for OFACs operations, licenses... More interesting license applications were put in by U.S. government agencies full discussion of the export Control Entity! Be used to engage in trade with embargoed countries and to deal with both and! A regulatory minefield reports to be issued which only required such reports to be issued which required. 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