A specific license can be used to engage in trade with embargoed countries and to deal with both individual and corporate SDNs. Dismiss. 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. Although limited in some ways to transactions involving the Government of Syria, the existing Rachel Alpert on LinkedIn: Treasury Issues Syria General License 23 To Aid In 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, Office of Terrorism Finance and Economic Sanctions Policy. 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. 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. New General Licenses OFAC issued six new general licenses on April 6 and five on April 7 which authorize certain types of transactions and implement wind-down periods with listed Russian banks for activities otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), as detailed in the chart below. 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. Photography by Steve Evans, unless otherwise noted. Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. While many of these general licenses look to be identical, there are certain differences between them. Build a Morning News Brief: Easy, No Clutter, Free! 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. 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. Dismiss. 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. The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. [FR Doc. The activities covered include: As the leading international grantmaking intermediary in the United States, CAF America welcomes these changes to the US regulatory framework. 0000035204 00000 n 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. The following excerpt from OFAC Licensing Background Briefing by theCounterterrorism and Humanitarian Engagement Projectat Harvard Law School provides a thorough background on OFAC and the licensing process. 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. Specific licenses are commonly used to obtain authorization for the release of SDNs blocked assets, but they can be utilized under various other scenarios as well. 0000035657 00000 n provided in . Similarly, OFAC used pre-existing E.O. Digital Forensics. By issuing General License J-1, OFAC has started to provide its answer, as this particular M_;C}EZrB"F${#4eq3mI4\/X|L@# XruR {WzGc d>dx%o%fjn,Vvoy{"i )u (@!%d%@B x@ hHk XD O8xo0]`{mPp}`lC]x'08k07x|AAkFA,"|=>f{nvO~! http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. 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?" . 0000002092 00000 n Issued last November, the Democratic Republic of the Congo Sanctions Regulations (DRCSR) contains general license authorization allowing payments from unblocked sources for the provision of generally licensed legal services with a new twist: no requirement for filing of a letter of intent or an engagement letter. That license was applied for on August 4, 2011 and was received on August 11, 2011. Further to our post about General License (GL) No. are blocked . Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 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. Hj 0 endstream endobj 595 0 obj <>stream 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. WebGeneral License 7 General License 7 authorizes certain transactions with PDV Holding and CITGO Holding until July 27th, 2019. Director, Office of Foreign Assets Control. Grade 10 and 12 level courses are offered by NIOS, Indian National Education Board established in 1989 by the Ministry of Education (MHRD), India. tuition and home schooling, secondary and senior secondary level, i.e. 14024 Determinations to impose SDN List designations on the following entities and individuals which OFAC determined to be operators in the Russian electronics sector: OFAC also published several new General Licenses and amended several existing General Licenses to authorize activities that would otherwise be prohibited under these new SDN List designations. 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. Call Us At (954) 767-6333. 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. OFAC issues general license that provide certain exceptions to the sanctions requirements such as involving information materials and the sale of agricultural products, medicines and medical devices. Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. xJx Mining and Metals Sector Determination and Designations. I strongly in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" Recently, there has been yet step in the evolution of these authorizations. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. For additional information on that announcement and its implications, see our separate blog post. of International Grantmaking, The How to? of Domestic Grantmaking. . Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. at a difficult time for the country of Afghanistan, as it faces the threat of a public health crisis, drought, and economic collapse. 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. 0000022366 00000 n 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 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. 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. Many countries facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply with. The Only Comprehensive Resource on U.S. Economic Sanctions. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities operating in Russia and against those assisting with Russias war efforts in Ukraine. Had a great experience here. 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.. Holding and CITGO Holding until July 27th, 2019 the sanctions giving, How! 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