list of ofac general licenses
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. 0000003814 00000 n First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a tuition and home schooling, secondary and senior secondary level, i.e. 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. 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. 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. The full article can be foundhere. 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. 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. 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. . Andrea M. Gacki, Director, Office of Foreign Assets Control. HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| 0000001755 00000 n I guess DOJ must have really needed to transact with some terrorists right away. Dismiss. have discontinued my MBA as I got a sudden job opportunity after 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. 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. Director, Office of Foreign Assets Control. 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. My childs preference to complete Grade 12 from Perfect E Learn was almost similar to other children. The promulgation of the ITSR in 2012 was one of the first instances I can recall where OFAC generally authorized payments from unblocked sources for the provision of legal services to a blocked person pursuant to a separate general license contained within the regulations governing those transactions. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx 0000035177 00000 n On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities 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. She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding. 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. 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. of International Grantmaking, The How to? of Domestic Grantmaking. 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. December 23, 2021 Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. [FR Doc. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. SUMMARY: The OFAC administers and enforces economic sanctions against countries and individuals, including those persons and entities designated as terrorists. Andrea M. Gacki, Director, Office of Foreign Assets Control. As the U.S. Department of the Treasury explains, [a] general license authorizes a particular type of transaction for a How does OFAC decide whether to grant a license? Note 1 to paragraph ( b ) (3) of 542.211: trailer <]/Prev 201093/XRefStm 1755>> startxref 0 %%EOF 623 0 obj <>stream 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 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. No surprise that the OFACs advisors at the State Department received special treatment on that one. 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. 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. helped me to continue my class without quitting job. H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H Our online courses offer unprecedented opportunities for people who would otherwise have limited access to education. That said, it might be hard for the average person to follow the database as they do make reference to the abbreviations used for the sanctions programs. 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. 0000022516 00000 n I will be pouring over this Excel spreadsheet for most of the weekend and should have some more insights to post on next week. 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. OF THE TREASURY (Feb. 24, 2023), https://home.treasury.gov/news/press-releases/jy1298. OFAC also used pre-existing E.O. If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. Jessie Krafft, Senior Vice-President for External Affairs, warns that While this development is greatly welcomed, CAF America urges all donors to continue to proceed with caution when giving directly to countries under OFAC sanctions. MBA is a two year master degree program for students who want to gain the confidence to lead boldly and challenge conventional thinking in the global marketplace. 0000016532 00000 n In addition, the Global Terrorism Sanctions Regulations (GTSR)which governs dealings with parties designated under E.O. Dismiss. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. 0000022436 00000 n Towards the aim, Perfect E learn has already carved out a niche for itself in India and GCC countries as an online class provider at reasonable cost, serving hundreds of students. These General Licenses go far to allow for more funding to aid the Afghan people, but donors should be careful to assess the risks of giving to Afghanistan even with these new permissions. 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. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued 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. 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