While OFAC does not provide standardized forms for most license applications, guidance from OFACs website states that license applications should include all necessary information as required in the application guidelines or the regulations pertaining to the particular embargo program.13 According to 31 CFR 501.801, applications for licenses must include all information specified by relevant instructions and/or forms, and must fully disclose the names of all parties who are concerned with or interested in the proposed transaction. Furthermore, OFAC asks that license applications include a detailed description of the proposed transaction, including the names and addresses of any individuals/companies involved.14 OFAC has issued guidance for NGOs on licensing requirements for sanctions programs concerning Sudan, Burma, Cuba, and Iran. These General License issuances and amendments included (but were not limited to): (i) the amendment of 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. If authorized legal services are provided to those parties, then the payment for those services or reimbursement for any incurred expenses must be specifically licensed or comply with 31 C.F.R. 0000035570 00000 n
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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. Thank you #OFAC for today's #Syria earthquake relief license. 0000035657 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. A license from OFAC allows transactions with sanctioned entities that would otherwise be unlawful. 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. exams to Degree and Post graduation level. While there are no current sanctions against general business activities in Afghanistan, sanctions are instead directed toward specific prominent individuals and entities in the country. 0000004091 00000 n
Dismiss. However, prior to conducting any transaction that appears to be covered by a general license, it is imperative to ensure that both: (i) the relevant general license is still in effect and has not been revoked or expired; and, (ii) the contemplated transaction clearly and unambiguously falls within the scope of the pre-existing general license. If you have any questions please contact him at 202-280-6370 or ferrari@falawpc.com. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. . 0000021961 00000 n
On February 3, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) published adetermination pursuant to sections1(a)(ii), 1(b), and 5 of Executive Order 14071and adetermination pursuant to section 1(a)(ii) of Executive Order 14071(Determinations) to implement the price cap policy for Russian petroleum products, building on earlier determinations related to Russian crude oil. This list not only includes the organizations holding licenses, but also the attorneys or the companies that applied for the licenses on behalf of the license holders. 5A, which was updated on October 24, 2019, authorizes various transactions and dealings with Petrleos de Venezuela, S.A. on or after January 22, 2020. Dismiss. The provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. Quantum What? The activities covered include: The official business of the U.S. government; Dismiss. develop their business skills and accelerate their career program. 13382. U"20 Pyy~jVq{1I)~|$uw^SHD On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. 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. 0000001176 00000 n
202304360 Filed 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. 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. By issuing General License J-1, OFAC has started to provide its answer, as this particular 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. Incidentally, there license has no expiration date. A general license authorizes a particular type of transaction for a class of persons without the need to apply for a license.9 A specific license is a written document issued by OFAC to a particular person or entity, authorizing a particular transaction in response to a written license application.10 The Code of Federal Regulations (CFR) is the collection of regulations setting out how the executive branch will interpret the parts of the U.S. Code that Congress charged it with enforcing. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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. 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 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. Note 1 to paragraph ( b ) (3) of 542.211: Weblist of ofac general licenses. Developing a conducive digital environment where students can pursue their 10/12 level, degree and post graduate programs from the comfort of their homes even if they are attending a regular course at college/school or working. Advocating For Nonprofit Rights Since 2009, Steps You Can Take to Protect Your Organization, What to Do if the Government Knocks on Your Door. For instance, just because you dont need a license to receive payment from a party designated under E.O. Pursuant to a Freedom of Information Act (FOIA) Request, the United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has released a list of parties holding OFAC licenses under a variety of different sanctions programs. OFAC imposed SDN List designations on the following individuals and entities for their roles in helping Russia: Russian Elite-Linked Businessman Tied to Illicit Financial Activity. So if the person reading the database does not know that IA is the abbreviated notation for a license issued pursuant to the Iranian Transactions Regulation (ITR) or that SDGT represents a license granted under the Global Terrorism Sanctions then they may have a hard time understanding what the licenses where granted for. have discontinued my MBA as I got a sudden job opportunity after Photography by Steve Evans, unless otherwise noted. In order to transfer assets as a specially designated national (SDN) or to engage in transactions involving an SDNs blocked assets, it is necessary to obtain a license from the Office of Foreign Asset Control (OFAC). 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. in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. 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 New General Licenses OFAC issued six new general licenses on April 6 and five on April 7 which authorize certain types of transactions and implement wind-down periods with listed Russian banks for activities otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), as detailed in the chart below. U.S. Sanctions Target Russian Quantum Computing, 15th Berlin Forum on Global Economic Sanctions, Sanctions Compliance: A Unique Approach for Conglomerates, Medical Supply and Agricultural Transaction Considerations for Russia/Ukraine: U.S. Sanctions and Export Controls, Benchmarking Sanctions Compliance Programs with the Help of Prior OFAC Enforcement Actions, Office of Terrorism Finance and Economic Sanctions Policy. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program successful learners are eligible for higher studies and to attempt competitive Certain financial institutions may still choose not to honor these licenses; thus finding a banking partner that will transfer funds into these regions will still be an important step.. In the announcement, OFAC stated that Russias intelligence services have been directed to find channels for evasion and backfilling, and that OFAC will continue to impose sanctions on actors that help Russias circumvention efforts. OF THE TREASURY (Feb. 24, 2023), https://home.treasury.gov/news/press-releases/jy1298. provided in . 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. 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. Due to 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. 0000016263 00000 n
[FR Doc. Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" 13224., Along with this recent issuance, OFAC has published. 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, WebThere are two types of OFAC licenses: general and specific. Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. For example, OFAC specific licenses issued under the Non-Proliferation of Weapons of Mass Destructions Sanctions Regulations (NPWMDSR) still require quarterly reports to be made for payments related to the provision of legal services to persons blocked under E.O. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. M_;C}EZrB"F${#4eq3mI4\/X|L@# XruR {WzGc
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