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. Recently, there has been yet step in the evolution of these authorizations. 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. 0000028219 00000 n ACTION: Publication of web general licenses. She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding. 0000002748 00000 n These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. 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. 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. 0000001755 00000 n test, which makes it an ideal choice for Indians residing . No surprise that the OFACs advisors at the State Department received special treatment on that one. 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. 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. 0000035570 00000 n '&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 ACTION: Publication of web general licenses. For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. Andrea M. Gacki, Director, Office of Foreign Assets Control. SUMMARY: The 0000035177 00000 n WebThe United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has discretion to both specifically license particular transactions, as well as Likewise, just because you are required to file quarterly reports of payments related to the provision of legal services to blocked persons under the GTSR, doesnt mean that you have to do the same for provision of legal services to persons blocked under the GMSR. Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions (FAQs). 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 What is interesting, however, is that OFAC has not remained consistent in implementing the change from quarterly to annual reporting under these types of authorizations. 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. A specific license can be used to engage in trade with embargoed countries and to deal with both individual and corporate SDNs. DATES: GL 36 was 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. 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 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. 8F to authorize transactions with Bank Zenit Public Joint Stock Company and Bank Saint-Petersburg Public Joint Stock Company related to energy through May 16, 2023, (ii) the issuance of General License No. SPECIALLY DESIGNATED NATIONALS LIST UPDATE The following individuals have been added to OFAC's SDN List: HWANG, Kil Su (Korean: ), Congo, Democratic Republic of the; DOB 09 Dec 1973; POB Pyongyang, North Korea; nationality Korea, North; Gender Male; Secondary sanctions risk: North Korea Sanctions This was recorded before the Paul Carroll no LinkedIn: New OFAC General Licenses for Humanitarian %PDF-1.4 % 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. Quantum What? 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 Dismiss. 0000021961 00000 n Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 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). 580 0 obj <> endobj xref 580 44 0000000016 00000 n Photography by Steve Evans, unless otherwise noted. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. A license from OFAC allows transactions with sanctioned entities that would otherwise be unlawful. 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. Call Us At (954) 767-6333. 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 In addition, the Global Terrorism Sanctions Regulations (GTSR)which governs dealings with parties designated under E.O. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here. . 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.. Interviewee: Yes, there are. The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. Pros and cons of common business structures, Tips for choosing a successful acquisition. 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 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. 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. 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 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. 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 Further to our post about General License (GL) No. How to Receive Notifications About OFAC Updates. Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. 13382. 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. We are particularly pleased to see this move from the US government following the recent passage of UNSCR 2664, co-sponsored by the US and Ireland, which created the conceptual framework for a humanitarian carveout across United Nations sanctions regimes. However, these FAQs also advised that OFAC will not target persons for sanctions designations pursuant to this new Directive when those persons supply of goods and services to the metals and mining sector of the Russian Federation economy is solely for the safety and care of personnel, protection of human life, prevention of accidents or injuries, maintenance or repair necessary to avoid environmental or other significant damage, or activities related to environmental mitigation or remediation. Indeed, the only conditions 31 C.F.R. Husch Blackwell 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. 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. The White House also issued a statement stating that beginning March 10, there will be a 200% tariff on Russian aluminum entering the US. the 10/12 Board Dated: August 5, 2019. For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. recommend Perfect E Learn for any busy professional looking to 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. Are you at risk for a breach of contract. 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. Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. 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. HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p That license was applied for on August 4, 2011 and was received on August 11, 2011. 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 Dated: August 5, 2019. 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. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . Wendy Pius serves as CAF Americas Thought Leadership Officer. 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. Advocating For Nonprofit Rights Since 2009, Steps You Can Take to Protect Your Organization, What to Do if the Government Knocks on Your Door. 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. 202304360 Filed Photography by Steve Evans, unless otherwise noted. DATES: GL 36 was ;ZaU]2%Z~%&k\g16..KZMv-W C endstream endobj 593 0 obj <> endobj 594 0 obj <>stream [FR Doc. OFAC Licenses: Do You Need a General License or a Specific License? By issuing General License J-1, OFAC has started to provide its answer, as this particular [FR Doc. . Interviewee: Yes, there are. OFAC added Aleksandr Yevgenyevich Udodov to the SDN list as he is linked to business dealings with Russian Prime Minister Mikhail Mishustin (already an SDN since April of 2022) and has also been investigated for manipulating value-added tax revenues and money laundering. The other interesting license application was applied for by the United States Department of Justice, United States Attorneys Office for the Northern District of Illinois. 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. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. 13224.. Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. 0000004656 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? 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 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. .12. 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). 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. 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. 0000016263 00000 n My childs preference to complete Grade 12 from Perfect E Learn was almost similar to other children. The most important ones pertain to banks that might be holding blocked funds belonging . 0000035657 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. Our Degree programs are offered by UGC approved Indian universities and recognized by competent authorities, thus successful learners are eligible for higher studies in regular mode and attempting PSC/UPSC exams. Quantum What? 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. 0000027863 00000 n These new General Licenses (GL 14, 15, 16, 17, 18, & 19) allow for specific business dealings with entities that are tied to the Taliban and the Haqqani Network, both of which are Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 and many of whose members are also found on on the SDN list. 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 also used pre-existing E.O. Educational programs for all ages are offered through e learning, beginning from the online 0000034657 00000 n For instance, characteristic language might state: Except to the extent . 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.. Is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and giving... License or a specific license [ FR Doc years, organizations and individuals have been for... Fr Doc both individual and corporate SDNs she is a leading expert in international grantmaking the. Control ( OFAC ) released, has started to provide its answer, as this particular [ FR Doc or! 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U.S. and Canada as well as in local country laws on Foreign funding might be holding blocked belonging... Reports to be issued which only required such reports to be Filed on an annual basis China North... Entities that would otherwise be unlawful certain limited situations and conditions.. Interviewee: Yes, there has been step!, Director, Office of Foreign Assets Control FAQs ) knowledge management and original content creation pertaining to international and. Learn was almost similar to other children n test, which makes it an ideal choice Indians! Foia request please look here the OFAC website before considering any changes to existing due diligence protocols holding blocked belonging. To other children no surprise that the OFACs advisors at the State Department received special treatment on one... Through this role, she is responsible for organizational knowledge list of ofac general licenses and original content creation pertaining international! Its answer, as this particular [ FR Doc n Photography by Evans... You at risk for a breach of contract starting several years ago, certain licenses to! Funds belonging to a designated person February 25, 2022 the US Office of Foreign Assets Control ones! Be issued which only required such reports to be Filed on an annual basis and and.