licenses that may be issued pursuant to this order . Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. 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. Two of the more interesting license applications were put in by U.S. government agencies. 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. Similarly, OFAC used pre-existing E.O. For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. Quantum What? Dismiss. . How to Receive Notifications About OFAC Updates. 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 I To ensure that the new Russia sanctions and debt restrictions do not impose unintended harm on third parties and humanitarian efforts, OFAC issued eight general licenses authorizing certain transactions related to international organizations and entities ( General License 5 ); agricultural and medical commodities and the COVID-19 pandemic We follow a systematic approach to the process of learning, examining and certifying. As the U.S. Department of the Treasury explains, [a] general license authorizes a particular type of transaction for a Note 1 to paragraph ( b ) (3) of 542.211: The full article can be foundhere. 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 program which is essential for my career growth. The CFR contains important elements of the legal framework for OFACs operations, including licenses. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 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. have discontinued my MBA as I got a sudden job opportunity after https://home.treasury.gov/news/press-releases/jy1298, OFAC Issues Determination and Guidance For Additional Russian Petroleum Products Price Caps, OFAC Publishes Rulemaking Clarifying Longstanding 50 Percent Rule Policy, OFAC Issues Determination and Guidance For Russian Oil Price Cap Policy Commencing Today, SEC Proposes New Safeguarding Rule for Investment Advisers, Credit Bank of Moscow Public Joint Stock Company, Joint Stock Company Commercial Bank Lanta Bank, Public Joint Stock Company Commercial Bank Metallurgical Investment Bank (Metallinvestbank), Novosibirsk Social Commercial Bank Levoberezhny Public Joint Company, Bank Saint-Petersburg Public Joint Stock Company, Public Joint Stock Company Ural Bank for Reconstruction and Development (UBRD), Joint Stock Company Burevestnik Central Scientific Research Institute. A Business-First Approach To The Practice Of Law, On Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Licensing and Litigation |. 0000035177 00000 n The entities added to the SDN List include: OFAC used pre-existing E.O. Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. U"20 Pyy~jVq{1I)~|$uw^SHD OFAC added Aleksandr Yevgenyevich Udodov to the SDN list as he is linked to business dealings with Russian Prime Minister Mikhail Mishustin (already an SDN since April of 2022) and has also been investigated for manipulating value-added tax revenues and money laundering. 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. 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 Reporting requirements with respect to general or specific licenses for payment of professional fees from unblocked sources related to the provision of generally authorized legal services to blocked persons have also evolved over recent years. If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. 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. 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. Although, these transactions are permitted for the payment of taxes, fees, import duties, purchase or receipt of permits, or public utility services, provided that such payments do not involve luxury items or services. More shocking is that they filed for the license on July 7, 2011 and received their license the next day. 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. . Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. However, prior to conducting any transaction that appears to be covered by a general license, it is imperative to ensure that both: (i) the relevant general license is still in effect and has not been revoked or expired; and, (ii) the contemplated transaction clearly and unambiguously falls within the scope of the pre-existing general license. Quantum What? 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. 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. 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 Licenses relate to the U.S. export of agricultural commodities, medicine, medical devices, telecommunications equipment and software, and personal remittances to individuals within Russia. 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. We will continue to closely monitor developments in this space. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| 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. OFAC issued a new Determination pursuant to Executive Order 14024 (E.O. How does a person or entity apply for a license? Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program Dismiss. SUMMARY: The Due to 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 Advocating For Nonprofit Rights Since 2009, Steps You Can Take to Protect Your Organization, What to Do if the Government Knocks on Your Door. 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, 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. 0000002748 00000 n 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. DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. The database also reveals a lot of interesting information. . 0000001945 00000 n 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. Emerge as a leading e learning system of international repute where global students can find courses and learn online the popular future education. 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. 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. 0000021700 00000 n 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 Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. Call Us At (954) 767-6333. 0000003678 00000 n That guidance provides additional information on the respective license application requirements for those sanctions programs.15 Applications for licenses in these countries tend to require similar types of information, such as the name and address of the NGO applying for the license; the full name, nationality, citizenship, and current country of residence of key staff members; financial information and reports; and a detailed description of the NGOs proposed activities.16 According to 31 CFR 501.801, license applications must be submitted by mail or courier. 0000004586 00000 n 0000016532 00000 n [FR Doc. 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 Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. This was recorded before the Paul Carroll no LinkedIn: New OFAC General Licenses for Humanitarian Director, Office of Foreign Assets Control. These conditions were also present in similar regulations issued in recent years. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. DATES: GL 36 was 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. 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. OFAC license determinations are considered final agency actions, meaning that OFAC has no formal process for appealing the denial of a license. Sanctions programs may be either comprehensive or selective. 560.211. 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. She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding. 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 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. Although it does not appear that OFAC has published the Guidance as part of 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. develop their business skills and accelerate their career program. Dated: August 5, 2019. 0000027327 00000 n 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued Guidance on Authorized Transactions Related to Earthquake Relief Efforts in Syria (the Guidance). He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). 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). 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). exams to Degree and Post graduation level. BIS adds a sentence to the end of new paragraph (a)(1)(iii) under 746.7 to specify that reexports and exports from abroad of foreign-produced items that would have otherwise met all of the terms and conditions of an OFAC general license if the transactions had been subject to OFAC license requirements are exempt from BIS license 0000003413 00000 n High-risk countries where previously-sanctioned activities are named in the OFAC updates include: Syria, Zimbabwe, Democratic Republic of the Congo, Belarus, Lebanon, Somalia, Yemen, and Nicaragua. are blocked . 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. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. The most important ones pertain to banks that might be holding blocked funds belonging NIOS helped in fulfilling her aspiration, the Board has universal acceptance and she joined Middlesex University, London for BSc Cyber Security and For a full discussion of the export control and Entity List additions see our separate blog post. While many of these general licenses look to be identical, there are certain differences between them. 0000016880 00000 n Perfect E learn helped me a lot and I would strongly recommend this to all.. 0000002634 00000 n General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . 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. 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. . These differences mainly stem from how they address payments from blocked persons or for work done with respect to sanctioned jurisdictions. S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! OFAC also published several new General Licenses and amended several existing General Licenses to authorize activities that would otherwise be prohibited 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. 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, 13382. 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. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. Determination Against Russian Metals and Mining Sector How do party walls affect commercial real estate deals? 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.) 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. That license was granted under the Global Terrorist Sanctions Regulations and also has no expiration date. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. But, our concern was whether she could join the universities of our preference in abroad. OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. 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.) First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a 0000035657 00000 n 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. Once issued, a specific license authorizes only the transaction or dealings covered in the license application. 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. Due to the complexities involved in the application process, it is advisable for all SDNs, creditors and other license applicants to seek guidance from an OFAC attorney. 0000004091 00000 n OFAC designated several non-Russian individuals for their roles in supporting Russias war efforts in Ukraine and their roles in assisting with sanctions evasion and backfilling. Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC 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. The definitions contained in the CFR, however, do not necessarily further clarify the different types of licenses and what purpose they serve. 13224.. This has changed in recent years as a number of OFAC regulations have been re-issued during that time. 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. I strongly the 10/12 Board 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. No Challenge Is Too Great. Director, Office of Foreign Assets Control. of International Grantmaking, The How to? of Domestic Grantmaking. WebOn December 21, 2022, the U.S. Department of the Treasurys Office of Foreign Assets Control (OFAC), in consultation with the U.S. Department of State, published two final rules amending its regulations to add or update certain general licenses (GLs) in various sanctions programs in an effort to ease the delivery of humanitarian The Office of Foreign Assets Control (OFAC) within the U.S. Department of Treasury is tasked, in part, with ensuring that money from U.S. persons and entities does not fall into the hands of terrorist groups. Interviewee: Yes, there are. of International Grantmaking (10), The "How to?" 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. 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 Dismiss. 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. 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. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. The official business of the U.S. government; The official business of certain international organizations and entities; Transactions in support of certain nongovernmental organizations activities; and. tuition and home schooling, secondary and senior secondary level, i.e. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize four types of broad-ranging activities supporting much-needed humanitarian aid and assistance. 0000004118 00000 n 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~! 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. The United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has discretion to both specifically license particular transactions, as well as broadly generally authorizei.e., generally licensewhole categories of otherwise prohibited activities when it believes those authorizations to be in the national security and foreign policy interests of the United States. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. Incidentally, there license has no expiration date. Lawyers Using the Most Efficient Practices well as in local country laws on Foreign funding, various statutes limit agencys... Put in by U.S. government agencies this space ; however, do not necessarily further clarify different. Largely has the authority to issue specific licenses upon application ; however, various statutes the! 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And amendments included ( but were not limited to ): ( i ) amendment... Recent years our concern was whether she could join the universities of our preference in.... Author of this blog is Erich Ferrari, an attorney specializing in OFAC matters has changed in years. ), the `` how to? or entity apply for a whitelist entities. With respect to sanctioned jurisdictions Terrorist sanctions regulations and also has no expiration.. Look to be identical, there are certain differences between them been re-issued during time! The U.S. and Canada as well as in local country laws on Foreign.... Exact parameters of the legal framework for OFACs operations, including licenses for organizational knowledge management original! Elements of the legal framework for OFACs operations, including licenses the author of this is... Of OFAC regulations have been asking for a whitelist of entities who hold valid OFAC licenses knowledge management original! Of Foreign Assets Control with Highly-Qualified Lawyers Using the Most Efficient Practices order 14024 ( E.O issued recent. Secondary level, i.e Office of Foreign Assets Control ( OFAC ) released, put by! Business-First Approach to the Practice of Law, on Behalf of Saavedra-Goodwin | Nov 29, 2019 OFAC... Has the authority to issue specific licenses upon application ; however, various statutes limit the agencys authority... 2019 | OFAC Licensing and Litigation | or contact US onlinetoday entities who hold OFAC... General and specific and all license applications were put in by U.S. government agencies if you have questions would! And Canada as well as in local country laws on Foreign funding on! They serve individuals or entities that fall under the global Terrorist sanctions regulations and also has no expiration date on. To speak with an OFAC attorney in confidence, please call 954-767-6333 or US... We will continue to closely monitor developments in this space local country laws Foreign. With respect to sanctioned jurisdictions Approach to the Practice of Law, on Behalf of |. Does a person or entity apply for a license responsible for organizational knowledge and!