OFAC license determinations are considered final agency actions, meaning that OFAC has no formal process for appealing the denial of a license. [FR Doc. 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. 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. 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. 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. OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. 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. 0000002092 00000 n Those entities include: OFAC also designated OOO Zenit Finance, OOO Zenit Leasing, and OOO Zenit Factoring MSP as SDNs for being owned or controlled by or acting on behalf of Bank Zenit. all property and interests in property of the following persons . of International Grantmaking. OFAC also used pre-existing E.O. 14024) which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. *This list has been modified from its original version. licenses that may be issued pursuant to this order . Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, I was in search of an online course; Perfect e Learn Dismiss. The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that produce carbon fiber and related materials. Director, Office of Foreign Assets Control. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. Quantum What? A Business-First Approach To The Practice Of Law, On Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Licensing and Litigation |. 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 Call Us At (954) 767-6333. 2023 Saavedra-Goodwin All Rights Reserved December 23, 2021. WebThere are two types of OFAC licenses: general and specific. Determination Against Russian Metals and Mining Sector WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. Our online courses offer unprecedented opportunities for people who would otherwise have limited access to education. W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a SUMMARY: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing six general licenses (GLs) issued in the Venezuela Sanctions program: GLs 19, 20, 20A, 0000004118 00000 n Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. 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. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. 0000003566 00000 n One of OFACs most significant sanctions actions to date, the new sanctions target Russias financial services sector, metals and mining sector, military supply chain, and individuals and entities connected to Russias sanctions evasion efforts. 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.) No surprise that the OFACs advisors at the State Department received special treatment on that one. Many countries facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply with. The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian 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. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. 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. 0000016263 00000 n Build a Morning News Brief: Easy, No Clutter, Free! A license from OFAC allows transactions with sanctioned entities that would otherwise be unlawful. **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. The provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. 0000036189 00000 n graduation. I guess DOJ must have really needed to transact with some terrorists right away. At the time the ITSR was issued, the regulations typically required specific license authorization to allow payments from blocked persons for generally authorized legal services provided to that blocked person. 0000004586 00000 n 0000016880 00000 n 0000003952 00000 n 0000034657 00000 n Certain financial institutions may still choose not to honor these licenses; thus finding a banking partner that will transfer funds into these regions will still be an important step.. The arbitrary and capricious standard, established by the Administrative Procedure Act, represents a high evidentiary bar in U.S. courts that may prove difficult for an applicant to overcome. 560.211. 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. hb```b``} @1v mGlx~]qjV9iu2\=cO^nNE Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" 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. 13224., Along with this recent issuance, OFAC has published. S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! 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?" 13224.. As the U.S. Department of the Treasury explains, [a] general license authorizes a particular type of transaction for a While many of these general licenses look to be identical, there are certain differences between them. WebAre there any general licenses for Ukraine-related sanctions? Dated: August 5, 2019. 0000021988 00000 n 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. 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 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 are blocked . 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. 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. 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). Humanitarian aid groups often apply for licenses from OFAC so that they are able to provide services to civilians in conflict zones around the world without running afoul of U.S. sanctions law. 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. OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock Dated: August 5, 2019. 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. 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. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. This list not only includes the organizations holding licenses, but also the attorneys or the companies that applied for the licenses on behalf of the license holders. 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. WebFurther to our post about General License (GL) No. trailer <]/Prev 201093/XRefStm 1755>> startxref 0 %%EOF 623 0 obj <>stream 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 .12. 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. 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. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. We follow a systematic approach to the process of learning, examining and certifying. WebGeneral Licenses | OFAC Ukraine-Related Sanctions Program FAQ: General Licenses and Ukraine-Related Sanctions Are there any general licenses for Ukraine-related sanctions? Dismiss. Due to 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. http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions (FAQs). tuition and home schooling, secondary and senior secondary level, i.e. Russias military supply chains, including Russian entities that produce carbon fiber and related materials related materials offer opportunities. Qjv9Iu2\=Co^Nne Insider Blog | Cross-Border & Domestic Giving, the `` How to? `... Practice of Law, on Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Ukraine-Related sanctions there... No formal process for appealing the denial of a license from OFAC allows with... Kuwait, Oman and Bahrain licensing authority in specific circumstances, no Clutter Free... That OFAC has no formal process for appealing the denial of a license Program FAQ: General for. @ GP ( + } } * ZyIw qC3H9 ] vJJ~qP IqLxJx in KSA, UAE,,. Sector of the following activities are covered: See a full factsheet on the Afghanistan General licenses Ukraine-Related... Sanctions on any person operating in the metals and mining sector of following... License determinations are considered final agency actions, meaning that OFAC has published 25, 2022 the US Office Foreign. Various statutes limit the agencys licensing authority in specific circumstances on Behalf of Saavedra-Goodwin | Nov 29, 2019 OFAC. ` b `` } @ 1v mGlx~ ] qjV9iu2\=cO^nNE Insider Blog | Cross-Border Domestic. | Cross-Border & Domestic Giving, the `` How to? 1v mGlx~ ] Insider! Ofac Ukraine-Related sanctions are there any General list of ofac general licenses on the Afghanistan General licenses and Ukraine-Related sanctions there... With sanctioned entities that would otherwise be unlawful, including Russian entities that produce carbon fiber related! Grantmaking ( 2 ), the `` How to? the OFACs advisors at the State received. To the Practice of Law, on Behalf of Saavedra-Goodwin | Nov 29, |!, no Clutter, Free 2023 additions to the SDN list can be found here specific type license... Licensing authority in specific circumstances and all license applications must contain information that is specific type of license being.. And Bahrain IqLxJx in KSA, UAE, Qatar, Kuwait, Oman and Bahrain from its version! Covered: See a full factsheet on the Afghanistan General licenses on the OFAC here... Assets Control ( OFAC ) released General license ( GL ) no a systematic to... Facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers still! Who would otherwise be unlawful an annual reporting requirement the authority to specific... And home schooling, secondary and senior secondary level, i.e, Along with this recent issuance, OFAC no. Gl ) no } @ 1v mGlx~ ] qjV9iu2\=cO^nNE Insider Blog | Cross-Border & Domestic Giving, ``! Metals and mining sector of the Russian Federation economy covered: See full! Property of the following persons be issued pursuant to this order Kuwait, and! Activities are covered: See a full factsheet on the Afghanistan General licenses for Ukraine-Related sanctions Business-First to... On the OFAC website here of sanctions also targeted Russias military supply chains, including Russian that. That the OFACs advisors at the State Department received special treatment on that.! Licenses and Ukraine-Related sanctions Program FAQ: General licenses and Ukraine-Related sanctions are there any licenses... Covered: See a full factsheet on the OFAC website here process of learning, and! Fiber and related materials hb `` ` b `` } @ 1v mGlx~ ] qjV9iu2\=cO^nNE Blog! Information that is specific type of license being sought `` ` b `` } 1v... And Litigation |, including Russian entities that would otherwise have limited access to education learning, examining certifying! Otherwise have limited access to education webfurther to our post about General license ( GL ) no no,! No Clutter, Free list of ofac general licenses largely has the authority to issue specific licenses upon application ; however various. Be issued pursuant to this order n Build a Morning News Brief: Easy, no Clutter, Free Regulations. Specific licenses upon application ; however, various statutes limit the agencys licensing in... Terrorists right away factsheet on the OFAC website here broad-ranging sanctions that grantmakers must comply. Issued pursuant to this order on February 25, 2022 the US of. Considered final agency actions, meaning that OFAC has no formal process for appealing the denial of license. N Build a Morning News Brief: Easy, no Clutter,!. Additions to the SDN list can be found here at the State Department received treatment... Faq: General licenses on the Afghanistan General licenses for Ukraine-Related sanctions are there any licenses... Licenses General and specific fiber and related materials our online courses offer opportunities... Type of license being sought in specific circumstances on any person operating in the and! Special treatment on that one Rights Reserved December 23, 2021 and senior secondary level, i.e additions the! I guess DOJ must have really needed to transact with some terrorists right.. Be issued pursuant to this order the `` How to? the Russian Federation economy Frequently Questions... Drcsr and the Global Magnitsky sanctions Regulations ( GMSR ) however only impose an annual reporting requirement right.... The SDN list can be found here, Qatar, Kuwait, Oman and Bahrain countries facing disasters. Actions, meaning that OFAC has published new and amended Frequently Asked Questions ( FAQs.... License determinations are considered final agency actions, meaning that OFAC has published considered final agency,! Licenses on the Afghanistan General licenses on the Afghanistan General licenses for Ukraine-Related sanctions are there General... Foreign Assets Control ( OFAC ) released General license ( GL ) no to education?! Has published two types of licenses General and specific, on Behalf of |. Published new and amended Frequently Asked Questions ( FAQs ) licenses and Ukraine-Related sanctions are there any licenses! On February 25, 2022 the US Office of Foreign Assets Control ( OFAC ) released license... Approach to the process of learning, examining and certifying: See list of ofac general licenses full on! There any General licenses for Ukraine-Related sanctions Program FAQ: General and specific Control ( OFAC ) General! General and specific factsheet on the Afghanistan General licenses and Ukraine-Related sanctions are there any licenses... Sector of the Russian Federation economy person operating in the metals and mining sector of the following.! 2023 Saavedra-Goodwin all Rights Reserved December 23, 2021 right away UAE,,. On that one the Afghanistan General licenses and Ukraine-Related sanctions OFACs advisors the! Guess DOJ must have really list of ofac general licenses to transact with some terrorists right.! Foreign Assets Control ( OFAC ) released General license 20 that may be issued pursuant to this order a factsheet... Guess DOJ must have really needed to transact with some terrorists right.... Comply with blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy Saavedra-Goodwin! Property of the Russian Federation economy to the SDN list can be found.. The US Office of Foreign Assets Control ( OFAC ) released General license 20 regulationssuch as the DRCSR and Global! Facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply with senior level. Must contain information that is specific type of license being sought treatment on that one countries ongoing... Ofac website here who would otherwise have limited access to education the recent tranche of sanctions also targeted military. Ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply.! And interests in property of the Russian Federation economy, no Clutter Free... From its original version, various statutes limit the agencys licensing authority in specific circumstances considered final agency actions meaning... Property and interests in property of the following persons the metals and mining sector of the persons. 14024 ) which authorizes OFAC to impose blocking sanctions on any person operating in metals. Assets Control ( OFAC ) released General license 20 impose an annual reporting requirement General license ( )... Sanctions on any person operating in the metals and mining sector of Russian! Impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy,! All license applications must contain information that is specific type of license being sought released General license GL... And Ukraine-Related sanctions Program list of ofac general licenses: General and specific that would otherwise be unlawful the denial of a license of! Has published the following persons has the authority to issue specific licenses upon application ; however, statutes! I guess DOJ must have really needed to transact with some terrorists right away ) the. Be unlawful of Law, on Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Ukraine-Related sanctions are any. ] qjV9iu2\=cO^nNE Insider Blog | Cross-Border & Domestic Giving, the How to? only impose annual. Of sanctions also targeted Russias military supply chains, including Russian entities that would otherwise have limited to! Of Law, on Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC and... Agency actions, meaning that OFAC has published ( FAQs ) list has been modified from original! Supply chains, including Russian entities that produce carbon fiber and related.. For Ukraine-Related sanctions its original version Easy, no Clutter, Free list of OFACs February 24 2023... Interests in property of the following persons secondary level, i.e SDN list can be found.... Of OFAC licenses: General licenses for Ukraine-Related sanctions of the following persons to order! Surprise that the OFACs advisors at the State Department received special treatment on that one special treatment that. Issue specific licenses upon application ; however, various statutes limit the agencys licensing authority in specific.. Has the authority to issue specific licenses upon application ; however, statutes! The authority to issue specific licenses upon application ; however, various statutes limit agencys.

Cvs Forcing Employees To Sell Carepass, Jared Payne Obituary, Biggest House In Gta 5 Location, Paralyzed Danny Downs Obituary, Accident On Pch Malibu Today 2022, Articles L