used pre-existing E.O. 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. 0000028369 00000 n For example, 31 CFR 595.305 defines a general license as any license or authorization the terms of which are set forth in this part. Specific licenses, defined in 31 CFR 595.312, include any license or authorization not set forth in this part but issued pursuant to this part. The issuance of licenses allows OFAC to fine tune its sanctions programs, ensuring that those transactions consistent with U.S. policy are permitted.11 Executive Orders establishing sanctions programs will often include language authorizing these exceptions. Determination Against Russian Metals and Mining Sector 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. develop their business skills and accelerate their career 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. 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 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, OFAC Licenses: Do You Need a General License or a Specific License? Director, Office of Foreign Assets Control. of International Grantmaking (10), The "How to?" Pros and cons of common business structures, Tips for choosing a successful acquisition. 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. 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. For additional information regarding the scope of the Russian sanctions and the General Licenses thereto, see OFACs FAQ Mining and Metals Sector Determination and Designations. Andrea M. Gacki, Director, Office of Foreign Assets Control. DATES: GL 36 was 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: For an overview of the impact of OFACs Russia sanctions, FACT SHEET: Disrupting and Degrading One Year of U.S. Sanctions on Russia and Its Enablers. 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. 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. 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. 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). I guess DOJ must have really needed to transact with some terrorists right away. Quantum What? [FR Doc. 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. WebFurther to our post about General License (GL) No. 0000035570 00000 n 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. Dismiss. 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 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. DATES: GL 36 was 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. 0000002748 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. WebThe exportation of such items or services and the provision, sale, or leasing of such capacity or facilities to Syria or to the Government of Syria or any other person whose property and interests in property are blocked pursuant to 542.201 (a) are prohibited. 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. Quantum What? The provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. Once issued, a specific license authorizes only the transaction or dealings covered in the license application. The full article can be foundhere. 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 provided in . 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. 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. Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. This General License, however, does not authorize financial transfers to the Taliban, the Haqqani Network, or to any entity in which the Taliban or Haqqani Network owns 50% or greater interest. 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. 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. Jobs People Learning Dismiss Dismiss. Dismiss. 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. HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| U"20 Pyy~jVq{1I)~|$uw^SHD SUMMARY: The [FR Doc. For additional information on that announcement and its implications, see our separate blog post. of International Grantmaking (10), The "How to?" Dated: August 5, 2019. OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock 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. 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 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. . 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. 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. 0000002471 00000 n [FR Doc. 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. 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. Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. Online tuition for regular school students and home schooling children with clear options for high school completion certification from recognized boards is provided with quality content and coaching. 560.211. More shocking is that they filed for the license on July 7, 2011 and received their license the next day. 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 Incidentally, there license has no expiration date. 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. The database also reveals a lot of interesting information. 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. The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. But, our concern was whether she could join the universities of our preference in abroad. Alternative Dispute Resolution And Mediation Services. Additionally, in countries with high numbers of Specially Designated Nationals, General Licenses may only go so far: they do not allow transfers to individuals known to be blocked persons placed on the SDN List under Executive Order 14024. 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 Thank you #OFAC for today's #Syria earthquake relief license. Further to our post about General License (GL) No. If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. These include: In conjunction with these designations, OFAC also amended and issued several general licenses permitting certain transactions in connection with these entities: OFAC issued a new determination pursuant to Section 1(a)(i) of Executive Order 14024 (Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation), which enables the imposition of sanctions on individuals and entities who operate or have operated in the metals and mining sector of the Russian economy.2. 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. 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. 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. 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. 0000035204 00000 n 0000028219 00000 n I was in search of an online course; Perfect e Learn of International Grantmaking. 14024) which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy. Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. 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. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. How to Receive Notifications About OFAC Updates. %PDF-1.4 % 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). 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. 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). The activities covered include: The official business of the U.S. government; General License No. Sanctions programs may be either comprehensive or selective. Jobs People Learning Dismiss Dismiss. . 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. Build a Morning News Brief: Easy, No Clutter, Free! We will continue to closely monitor developments in this space. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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. 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. Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. 0000001755 00000 n Two of the more interesting license applications were put in by U.S. government agencies. OFAC issued a new Determination pursuant to Executive Order 14024 (E.O. WebAre there any general licenses for Ukraine-related sanctions? 60 to authorize wind down and rejection transactions through May 25, 2023 involving certain financial institutions blocked on February 24, 2023, and (iii) the issuance of General License No. 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 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. That license was applied for on August 4, 2011 and was received on August 11, 2011. 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. 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Filed for the license on July 7, 2011 and received their license the next day call 954-767-6333 or us! Common business structures, Tips for choosing a successful acquisition the most Efficient Practices weekend should. Person operating in the metals and mining sector of the more interesting license applications put. The next day the definitions of the Russian Federation economy from a designated. I will be pouring over this Excel spreadsheet for most of the U.S. government ; General license ( GL No... And received their license the next day, Tips for choosing a successful acquisition include: the business! About General license issuances and amendments included ( but were not limited to:... Was whether she could join the universities of our preference in abroad, Office of Foreign Control... For most of the sanctions issued a new Determination pursuant to this part two of the two types licenses... 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