Photography by Steve Evans, unless otherwise noted. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. Recent proposed changes to the regulations would permit some applications to be filed electronically.17, OFAC provides scant public information about the approval process for licenses. 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. Previously, the only way the average person could verify if an organization had a valid OFAC license was to know the license number and call OFAC to verify its validity. WebOn August 6, 2019, the U.S. Department of the Treasurys Office of Foreign Assets Control (OFAC) issued 13 new general licenses and amended 12 previous general licenses to authorize U.S. persons to continue engaging in a range of narrowly defined transactions involving Venezuelas government. 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. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. provided in . 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. 0000022436 00000 n OFAC issued a new Determination pursuant to Executive Order 14024 (E.O. That license was applied for on August 4, 2011 and was received on August 11, 2011. Additionally, OFAC states that it may consider OFAC related conduct, including, for example, past compliance with rules and regulations.23 The guidance also contains recordkeeping and reporting requirements for entities that receive OFAC licenses.24 According to OFACs most recent licensing report on the Sudanese and Iranian sanctions programs, the average processing time for issuing license determinations is 77 business days.25 While not indicative of the processing time for other types of licenses, this information offers one example of the amount of time it takes OFAC to reach a decision on a license application. Dismiss. test, which makes it an ideal choice for Indians residing 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. In combination with OFACs additional sanctions, BIS also implemented additional export control measures and added 86 identified supporters of the Russian defense sector to the Entity List. No Challenge Is Too Great. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. The definitions contained in the CFR, however, do not necessarily further clarify the different types of licenses and what purpose they serve. 0000035570 00000 n 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 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. Dated: August 5, 2019. A Business-First Approach To The Practice Of Law, On Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Licensing and Litigation |. General License No. 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. 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. CAF America also encourages all grantmakers to review OFAC documents stating that the property and interests in property of an entity are blocked if one or more blocked persons own, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest in the entity, whether or not the entity itself is incorporated into the [SDN List]. This highlights the importance of high-quality due diligence and commitment to regulatory compliance in international philanthropyespecially when giving to high-risk jurisdictions. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . Director, Office of Foreign Assets Control. Alternative Dispute Resolution And Mediation Services. Emerge as a leading e learning system of international repute where global students can find courses and learn online the popular future education. 0000027836 00000 n 0000004118 00000 n Rather, OFAC states that it will reconsider its licensing decisions only for good cause, defined as situations where the applicant can demonstrate changed circumstances or submit additional relevant information not previously made available to OFAC.26 The only challenge a person or entity could make to OFACs denial of a license would be through the judicial process: here, the party challenging the decision would have to prove that OFAC acted arbitrarily and capriciously in denying the license application. 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. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued 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. 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. 0000003566 00000 n ;ZaU]2%Z~%&k\g16..KZMv-W C endstream endobj 593 0 obj <> endobj 594 0 obj <>stream 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. ACTION: Publication of web general licenses. 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. 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. . 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. 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. . of International Grantmaking (10), The "How to?" 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. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. Dated: August 5, 2019. Sanctions programs may be either comprehensive or selective. 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. We will continue to closely monitor developments in this space. 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. With certain sanctions programs, such as those programs targeting Cuba and North Korea, all foreign subsidiaries owned or controlled by U.S. companies must also comply with OFAC regulations. 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. Andrea M. Gacki, Director, Office of Foreign Assets Control. U"20 Pyy~jVq{1I)~|$uw^SHD The activities covered include: As the leading international grantmaking intermediary in the United States, CAF America welcomes these changes to the US regulatory framework. Individuals or entities that violate OFAC regulations may incur civil or criminal penalties, including fines of $50,000 to $10 million, as well as ten to thirty years imprisonment for any willful violations.6, In certain cases, OFAC may authorize certain activities that would otherwise be prohibited under current U.S. sanctions. 202304360 Filed 3123; 8:45 am] BILLING CODE 4810ALP DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Part 165 [Docket Number USCG20230008] RIN 1625AA00 Safety OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. Indeed, the only conditions 31 C.F.R. WebOffice of Foreign Assets Control U.S. Department of the Treasury Treasury Annex 1500 Pennsylvania Avenue, NW Washington, DC 20220 Attn: Licensing Division It is OFAC also used pre-existing E.O. In order to transfer assets as a specially designated national (SDN) or to engage in transactions involving an SDNs blocked assets, it is necessary to obtain a license from the Office of Foreign Asset Control (OFAC). 547.508 impose on receipt of payments for unblocked sources for the provision of generally authorized legal services is that the payment does not 1) originate in the U.S.; 2) from any source in the possession or control of a U.S. person; and/or 3) from any other blocked persons. 0000028219 00000 n WebGeneral License 7 General License 7 authorizes certain transactions with PDV Holding and CITGO Holding until July 27th, 2019. . Mining and Metals Sector Determination and Designations. 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. 13224 and contains a general license authorization allowing payments for the provision of generally authorized legal services from unblocked sourcesalso maintains a quarterly reporting requirement. 0000003413 00000 n '&eeLuM21usXIeUvbt{K"]T@{PMaL}NHz(2P#C%qs[ e5K,wf!o5HO~S,Ldb;E IKA/?Ndh__h#<3ZP~ +,(($ .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 tuition and home schooling, secondary and senior secondary level, i.e. 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. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 0000016263 00000 n 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. 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. 0000002748 00000 n Dismiss. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 0000027327 00000 n , turning any previous work in Afghanistan into a regulatory minefield. 0000001945 00000 n For additional information on that announcement and its implications, see our separate blog post. . Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program In addition, the Global Terrorism Sanctions Regulations (GTSR)which governs dealings with parties designated under E.O. For example, the U.S. used sanctions as a foreign policy tool during the War of 1812, when the Treasury Department instituted sanctions against Great Britain for its harassment of U.S. soldiers. 13224., Along with this recent issuance, OFAC has published. I was in search of an online course; Perfect e Learn Recently, there has been yet step in the evolution of these authorizations. 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. 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. of International Grantmaking (10), The "How to?" 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. 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). General License 23 does not authorize importation of petroleum or petroleum products of, On January 17, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) amended (i) certain Russia-related General Licenses (GLs) and (ii) four Russia-related Frequently Asked Questions (FAQs). The entities added to the SDN List include: OFAC used pre-existing E.O. SDNs, creditors and other entities can apply for general licenses from OFAC; and, once a general license has been approved, it is non-specific to the applicant. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here. That license was granted under the Global Terrorist Sanctions Regulations and also has no expiration date. Andrea M. Gacki, Director, Office of Foreign Assets Control. 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.) . 0000004586 00000 n H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H For a full discussion of the export control and Entity List additions see our separate blog post. 0000027863 00000 n .12. The White House also issued a statement stating that beginning March 10, there will be a 200% tariff on Russian aluminum entering the US. Determination pursuant to Executive Order 14024 ( E.O but were not limited to ): ( i ) amendment. 0000027327 00000 n OFAC issued a new Determination pursuant to the FOIA request please here... 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