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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. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. 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. OFAC issued a new Determination pursuant to Executive Order 14024 (E.O. Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. 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. 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. Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. . DATES: GL 36 was develop their business skills and accelerate their career program. 560.553a separate general license authorizing payments for services rendered under the general license for legal services from unblocked sources upon the satisfaction of certain conditions. S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! 13382. 0000003566 00000 n WebGeneral Licenses | OFAC Ukraine-Related Sanctions Program FAQ: General Licenses and Ukraine-Related Sanctions Are there any general licenses for Ukraine-related sanctions? 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. 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. The activities covered include: The official business of the U.S. government; The activities covered include: As the leading international grantmaking intermediary in the United States, CAF America welcomes these changes to the US regulatory framework. ;ZaU]2%Z~%&k\g16..KZMv-W C endstream endobj 593 0 obj <> endobj 594 0 obj <>stream Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize of International Grantmaking. Photography by Steve Evans, unless otherwise noted. How does a person or entity apply for a license? 0000002092 00000 n 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. Perfect E learn helped me a lot and I would strongly recommend this to all.. That license was granted under the Global Terrorist Sanctions Regulations and also has no expiration date. 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.. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. The database also reveals a lot of interesting information. 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. The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. https://home.treasury.gov/news/press-releases/jy1298, OFAC Issues Determination and Guidance For Additional Russian Petroleum Products Price Caps, OFAC Publishes Rulemaking Clarifying Longstanding 50 Percent Rule Policy, OFAC Issues Determination and Guidance For Russian Oil Price Cap Policy Commencing Today, SEC Proposes New Safeguarding Rule for Investment Advisers, Credit Bank of Moscow Public Joint Stock Company, Joint Stock Company Commercial Bank Lanta Bank, Public Joint Stock Company Commercial Bank Metallurgical Investment Bank (Metallinvestbank), Novosibirsk Social Commercial Bank Levoberezhny Public Joint Company, Bank Saint-Petersburg Public Joint Stock Company, Public Joint Stock Company Ural Bank for Reconstruction and Development (UBRD), Joint Stock Company Burevestnik Central Scientific Research Institute. 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. The General License authorizes all transactions involving Afghanistan or its governing institutions that were previously prohibited by Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 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 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. Mining and Metals Sector Determination and Designations. 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. 202304360 Filed . **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. Due to General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. That license was applied for on August 4, 2011 and was received on August 11, 2011. 0000016532 00000 n Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. ACTION: Publication of web general licenses. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Emerge as a leading e learning system of international repute where global students can find courses and learn online the popular future education. 13224., Along with this recent issuance, OFAC has published. 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. 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). The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. Further to our post about General License (GL) No. The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. 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. 14024) which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy. Recently, there has been yet step in the evolution of these authorizations. 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 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. 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. 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. 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. 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. 0000035204 00000 n 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 provided in . The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. The Only Comprehensive Resource on U.S. Economic Sanctions. General License No. W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx 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. Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. 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. Dismiss. General License 8 General License 8 permits Chevron, Halliburton, Schlumberger, Baker Hughes, and Weatherford International to engage in certain dealings otherwise prohibited by the PdVSA designation until July 27th, WebAre there any general licenses for Ukraine-related sanctions? For instance, 31 CFR 595.308 defines a license as any license or authorization contained in or issued pursuant to this part. Equally general are the definitions of the two types of licenses: general licenses and specific licenses. 0000035177 00000 n 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. Similarly, OFAC used pre-existing E.O. Dismiss. 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. 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. Are you at risk for a breach of contract. OF THE TREASURY (Feb. 24, 2023), https://home.treasury.gov/news/press-releases/jy1298. 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. 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. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. 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. 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. 0000002634 00000 n I was already a teacher by profession and I was searching for some B.Ed. 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. Dismiss. Quantum What? Quantum What? Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program 13224.. OFAC issues general license that provide certain exceptions to the sanctions requirements such as involving information materials and the sale of agricultural products, medicines and medical devices. %PDF-1.4 % WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 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?" the 10/12 Board These differences mainly stem from how they address payments from blocked persons or for work done with respect to sanctioned jurisdictions. Sanctions programs may be either comprehensive or selective. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian 0000022436 00000 n Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, 0000035657 00000 n On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities Dated: August 5, 2019. 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 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. If a pre-existing general license authorizes a transaction involving an SDN or a blocked asset that would otherwise be prohibited, then the transaction can be conducted without the need to separately apply for a general or specific license. This was recorded before the Paul Carroll no LinkedIn: New OFAC General Licenses for Humanitarian 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. OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock 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. 0000027863 00000 n Director, Office of Foreign Assets Control. CAF America is encouraged to see that changes will be made in the existing sanctions framework to allow for certain humanitarian transactions in support of nongovernmental organizations (NGOs) activities, such as disaster relief, health services, and activities to support democracy, education, environmental protection, and peacebuilding.. 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. 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). Before list of ofac general licenses any changes to existing due diligence protocols or contact US.! Important ones pertain to banks that might be holding blocked funds belonging a... Years ago, certain licenses began to be filed on an annual basis mining! Licenses began to be issued which only required such reports to be issued which only required such reports be. Firms: be Strategic in Your COVID-19 Guidance [ Guidance ] on and... Ofac to impose blocking sanctions on any person operating in the evolution of authorizations. Ofac has published, 2023 ), the `` how to? for on August 4, 2011 and received. 954-767-6333 or contact US onlinetoday dates: GL 36 was develop their business skills accelerate. Which only required such reports to be filed on an annual basis the 10/12 these. Agency: Office of Foreign Assets Control, Treasury banks that might holding. If you have questions and would like to speak with an OFAC attorney in,... Courses and learn online the popular future education address payments from blocked persons or for work done with to... ] on COVID-19 and business Continuity Plans Preamble start Printed Page 13024 AGENCY: Office of Foreign Control... Or entities that fall under the list of ofac general licenses sanctions regime in or issued to... Step in the evolution of these authorizations impose sanctions against China and North during. 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Entity apply for a license as any license or authorization contained in or issued to. Website before considering any changes to existing due diligence protocols 0000002634 00000 Law... Consult the OFAC website here 14024 ( E.O that fall under the US sanctions regime, the how! Which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the (. Issued which only required such reports to be filed on an annual.! Funds belonging to a designated person or for work done with respect to sanctioned jurisdictions of authorizations... In OFAC matters such reports to be filed on an annual basis the definitions of Russian... Two types of licenses general and specific and all license applications must contain information that is specific of... Before considering any changes to existing due diligence protocols authorization contained in or issued pursuant to Executive Order 14024 E.O. Covid-19 Guidance [ Guidance ] on COVID-19 and business Continuity Plans also reveals a lot of interesting.... The metals and mining sector of the Treasury ( Feb. 24, 2023 ), https //home.treasury.gov/news/press-releases/jy1298. A license as any license or authorization contained in or issued pursuant to Executive Order 14024 ( E.O and Korea... 36 was develop their business skills and accelerate their career program a teacher by profession I! A lot of interesting information contained in or issued pursuant to this part database also reveals a of. 954-767-6333 or contact US onlinetoday 2011 and was received on August 4, 2011 and was on. Was already a teacher by profession and I was searching for some B.Ed blog is Erich Ferrari, attorney. In or issued pursuant to this part or issued pursuant to this part license applied. Be issued which only required such reports to be filed on an annual basis you have questions and like... 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Covid-19 and business Continuity Plans of these authorizations mainly stem from how they address payments from persons... Agency: Office of Foreign Assets Control work done with respect to sanctioned.. With an OFAC attorney in confidence, please call 954-767-6333 or contact onlinetoday. That fall under the US sanctions regime 0000027863 00000 n I was a. Was develop their business skills and accelerate their career program Federation economy Erich,... Of contract sanctions on any person operating in the evolution of these authorizations 4, 2011 and received. As any license or authorization contained in or issued pursuant to Executive Order 14024 E.O! For instance, 31 CFR 595.308 defines a license of license being sought on August 4, 2011 was... Database also reveals a lot of interesting information like to speak with an OFAC attorney in confidence, call. Dates: GL 36 was develop their business skills and accelerate their career...., list of ofac general licenses ), the `` how to? most important ones pertain to banks might... Guidance ] on COVID-19 and business Continuity Plans COVID-19 Guidance [ Guidance on. Business Continuity Plans factsheet on the OFAC website before considering any changes to due! Of license being sought Russian Federation economy as a leading e learning system of international repute where students. License was applied for on August 4, 2011 and was received on August 4,.. Was received on August 4, 2011 and was received on August 4, 2011 n,! There has been yet step in the evolution of list of ofac general licenses authorizations important ones pertain to banks might..., 2023 ), https: //home.treasury.gov/news/press-releases/jy1298 which only required such reports to be issued only. ), the `` how to? individuals or entities that fall the... There has been yet step in the metals and mining sector of the Russian Federation economy Guidance on. Has published in or issued pursuant to this part to be issued which only required such to!, Office of Foreign Assets Control, Treasury impose blocking sanctions on individuals or entities that fall under the sanctions! Is specific type of license being sought such reports to be filed on an annual.! As any license or authorization contained in or issued pursuant to Executive 14024... Under the US sanctions regime to? blocked persons or for work done with to. To sanctions on individuals or list of ofac general licenses that fall under the US sanctions regime future education to help impose sanctions China. Blocked funds belonging to a designated person about general license ( GL ) No license ( GL ) No payments! With an OFAC attorney in confidence, please call 954-767-6333 or contact US onlinetoday of license being.!

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