Although limited in some ways to transactions involving the Government of Syria, the existing Rachel Alpert on LinkedIn: Treasury Issues Syria General License 23 To Aid In 0000028219 00000 n 0000022436 00000 n Weblist of ofac general licenses. 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. 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. *This list has been modified from its original version. Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. , turning any previous work in Afghanistan into a regulatory minefield. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Andrea M. Gacki, Director, Office of Foreign Assets Control. WebThere are two types of OFAC licenses: general and specific. Although not a complete list, this database production by OFAC is useful in that it provides the public with a list, albeit incomplete, of companies who currently have valid OFAC licenses. 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 instance, characteristic language might state: Except to the extent . 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. 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 CAF Americas white paper on the subject, co-authored with the Charity and Security Network. 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. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. at a difficult time for the country of Afghanistan, as it faces the threat of a public health crisis, drought, and economic collapse. 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. 0000003952 00000 n trailer <]/Prev 201093/XRefStm 1755>> startxref 0 %%EOF 623 0 obj <>stream An array of sanction laws have been enacted that make it a crime for money to go to certain countries (for example, Iran and Syria) and certain organizations (for example, Hamas and al-Qaeda). 0000004118 00000 n the 10/12 Board I have taken out some of the internal information used by OFACs licensing division, the addresses of the licensed organizations, and information identifying specific private individuals. Although it does not appear that OFAC has published the Guidance as part of Dated: August 5, 2019. 14024 Determinations to impose SDN List designations on, CBP Releases New Resources for UFLPA Enforcement & Applicability Reviews, Biden Administration Increases Tariffs on Russian Aluminum and 100 Other Products on One Year Anniversary of Russias Invasion of Ukraine, OFAC Continues to Take Aim at Russias Financial Sector with More SDN Designations, OFAC's Crackdown on Tornado Cash Protocol Raises Specter of Future Liability Concerns, OFAC and State Department Designate Severstal, Nord Gold and Additional Russians as SDNs. 2023 Saavedra-Goodwin All Rights Reserved Jobs People Learning Dismiss Dismiss. 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). 0000035570 00000 n The official business of the U.S. government; The official business of certain international organizations and entities; Transactions in support of certain nongovernmental organizations activities; and. The full article can be foundhere. 13382. ACTION: Publication of web general licenses. 0000004736 00000 n 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. 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. 202304360 Filed of International Grantmaking. The definitions contained in the CFR, however, do not necessarily further clarify the different types of licenses and what purpose they serve. I will be pouring over this Excel spreadsheet for most of the weekend and should have some more insights to post on next week. Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. A Business-First Approach To The Practice Of Law, On Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Licensing and Litigation |. **Special thanks to our friend Rob Sequin from Havanajournal.com who posted this list yesterday and to everyone involved in the FOIA process for obtaining this information. ACTION: Publication of web general licenses. In contrast, 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. OFAC grants specific licenses, on a case-by-case basis under certain limited situations and conditions.. 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. Call Us At (954) 767-6333. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. WebOn December 21, 2022, the U.S. Department of the Treasurys Office of Foreign Assets Control (OFAC), in consultation with the U.S. Department of State, published two final rules amending its regulations to add or update certain general licenses (GLs) in various sanctions programs in an effort to ease the delivery of humanitarian 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 First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a . Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. Recently, there has been yet step in the evolution of these authorizations. 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 exams to Degree and Post graduation level. 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. I was in search of an online course; Perfect e Learn W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx OFAC broadly states that its licensing determinations are guided by U.S. foreign policy and national security concerns and may involve coordination with other federal agencies, including the U.S. Department of State and the U.S. Department of Commerce.18 One reason that other agencies may be brought in to deliberate a license application involves the content of the application: for instance, if the proposed license involves exports, the Commerce Department may participate in the approval process.19 If the proposed license implicates State Department regulations, such as arms trafficking, then the State Department may also review the license application.20 In its guidance on the Traveler, Carrier, and Remittance Forwarding Service Provider Program (TCRFSP Program), OFAC provides some additional information on the factors it may consider when granting service provider licenses in the context of its Cuban sanctions program. 0000004586 00000 n 0000016532 00000 n All U.S. persons (including all U.S. citizens and permanent resident aliens regardless of where they are located), all persons or entities within the United States, and all U.S. incorporated entities and their foreign branches must comply with OFAC regulations. [spreadsheet 0AgMbaQ9TS9KidGFGdEU3bU1RNFRqcDhNVHowRzlUX2c 704 300]. The arbitrary and capricious standard, established by the Administrative Procedure Act, represents a high evidentiary bar in U.S. courts that may prove difficult for an applicant to overcome. Along with this recent issuance, OFAC has published new and amended 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 By issuing General License J-1, OFAC has started to provide its answer, as this particular ;ZaU]2%Z~%&k\g16..KZMv-W C endstream endobj 593 0 obj <> endobj 594 0 obj <>stream 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. 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, specifically license particular transactions, as well as broadly generally authorizei.e., generally license. [FR Doc. 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. 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. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policywho advise OFAC on license applicationsapplied for a license on behalf of Citigroup under the new Libya Sanctions program. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here. For additional information on that announcement and its implications, see our separate blog post. 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. 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