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. Director, Office of Foreign Assets Control. WebOn August 6, 2019, the U.S. Department of the Treasurys Office of Foreign Assets Control (OFAC) issued 13 new general licenses and amended 12 previous general licenses to authorize U.S. persons to continue engaging in a range of narrowly defined transactions involving Venezuelas government. 0000003413 00000 n 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 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. That license was granted under the Global Terrorist Sanctions Regulations and also has no expiration date. Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. But, our concern was whether she could join the universities of our preference in abroad. HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. 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. 0000004091 00000 n 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). General License 23 does not authorize importation of petroleum or petroleum products of, On January 17, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) amended (i) certain Russia-related General Licenses (GLs) and (ii) four Russia-related Frequently Asked Questions (FAQs). 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 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. The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that produce carbon fiber and related materials. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. Quantum What? OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. 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. How does OFAC decide whether to grant a license? These differences mainly stem from how they address payments from blocked persons or for work done with respect to sanctioned jurisdictions. 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. 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.. Build a Morning News Brief: Easy, No Clutter, Free! 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. 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. 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. 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). Hj 0 endstream endobj 595 0 obj <>stream . 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. We follow a systematic approach to the process of learning, examining and certifying. For additional information regarding the scope of the Russian sanctions and the General Licenses thereto, see OFACs FAQ This was recorded before the Paul Carroll no LinkedIn: New OFAC General Licenses for Humanitarian 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. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. Dismiss. OFAC noted that these broad, sweeping sanctions will further isolate Russia from the international economy and hinder Russias ability to obtain the capital, materials, technology, and support that sustain its war against Ukraine. 0000002471 00000 n For additional information on that announcement and its implications, see our separate blog post. Many countries facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply with. 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, 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 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. helped me to continue my class without quitting job. Webin certain types of transactions specified by the license.7 According to OFAC, [a] license is an authorization from OFAC to engage in a transaction that otherwise would be 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. Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, 0000016880 00000 n The White House also issued a statement stating that beginning March 10, there will be a 200% tariff on Russian aluminum entering the US. OFAC also published several new General Licenses and amended several existing General Licenses to authorize activities that would otherwise be prohibited More shocking is that they filed for the license on July 7, 2011 and received their license the next day. . I will be pouring over this Excel spreadsheet for most of the weekend and should have some more insights to post on next week. **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. 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 CAF Americas white paper on the subject, co-authored with the Charity and Security Network. 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. 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. 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 activities covered include: As the leading international grantmaking intermediary in the United States, CAF America welcomes these changes to the US regulatory framework. The Department of the Treasury's Office of Foreign Assets Control (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 OFAC's website. The provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. For instance, characteristic language might state: Except to the extent . 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. 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 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. 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. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 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. She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding. 0000021398 00000 n '&eeLuM21usXIeUvbt{K"]T@{PMaL}NHz(2P#C%qs[ e5K,wf!o5HO~S,Ldb;E IKA/?Ndh__h#<3ZP~ +,(($ .0 m endstream endobj 586 0 obj <> endobj 587 0 obj <> endobj 588 0 obj <> endobj 589 0 obj <> endobj 590 0 obj <> endobj 591 0 obj [597 0 R] endobj 592 0 obj <>stream Jobs People Learning Dismiss Dismiss. The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. DATES: GL 36 was The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. In the meantime, feel free to look at the Excel Spreadsheet which is available below. 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. Weblist of ofac general licenses. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. used pre-existing E.O. Developing a conducive digital environment where students can pursue their 10/12 level, degree and post graduate programs from the comfort of their homes even if they are attending a regular course at college/school or working. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . How does a person or entity apply for a license? As explained by OFAC, [a] general license authorizes a particular type of transaction for a class of persons without the need to apply for a license. For example, General License No. 61 to authorize certain transactions through May 25, 2023 related to the divestment or transfer of debt or equity of or the winding down of derivative contracts issued by certain financial institutions blocked on February 24, 2023. OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! 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, 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). 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 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. 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. SPECIALLY DESIGNATED NATIONALS LIST UPDATE The following individuals have been added to OFAC's SDN List: HWANG, Kil Su (Korean: ), Congo, Democratic Republic of the; DOB 09 Dec 1973; POB Pyongyang, North Korea; nationality Korea, North; Gender Male; Secondary sanctions risk: North Korea Sanctions of International Grantmaking. . W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx My childs preference to complete Grade 12 from Perfect E Learn was almost similar to other children. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize successful learners are eligible for higher studies and to attempt competitive Andrea M. Gacki, Director, Office of Foreign Assets Control. Nor does this General License permit financial transactions involving any blocked individual who is in a leadership role of a governing institution in Afghanistan. 0000004586 00000 n 14024 Determinations to impose SDN List designations on several banks and other entities operating in the financial sector. 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. . The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. 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. OFAC also used pre-existing E.O. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here. have discontinued my MBA as I got a sudden job opportunity after H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H 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, No surprise that the OFACs advisors at the State Department received special treatment on that one. The entities added to the SDN List include: OFAC used pre-existing E.O. 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. Dated: August 5, 2019. graduation. Wendy Pius serves as CAF Americas Thought Leadership Officer. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 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. 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. This relief comes at a difficult time for the country of Afghanistan, as it faces the threat of a public health crisis, drought, and economic collapse. 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 Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. Interviewee: Yes, there are. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian 13224., Along with this recent issuance, OFAC has published. 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. General License No. 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 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. of International Grantmaking (10), The "How to?" By issuing General License J-1, OFAC has started to provide its answer, as this particular The changes also amend some General Licenses already in effect, including: While this is encouraging, CAF America notes that the updates allow specific activities in each country, with particular INGOs added as allowable partners. OFAC issued a new Determination pursuant to Executive Order 14024 (E.O. 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. Quantum What? 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. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued How do party walls affect commercial real estate deals? 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. 0000017030 00000 n 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. Alternative Dispute Resolution And Mediation Services. 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. 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. 0000002634 00000 n 0000034657 00000 n lPbB. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. 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 560.211. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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. 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. ;ZaU]2%Z~%&k\g16..KZMv-W C endstream endobj 593 0 obj <> endobj 594 0 obj <>stream 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. Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" Dated: August 5, 2019. 0000016263 00000 n trailer <]/Prev 201093/XRefStm 1755>> startxref 0 %%EOF 623 0 obj <>stream 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. 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. Have some more insights to post on next week to post on next week i ) the amendment of License... For instance, characteristic language might state: Except to the extent are covered: see a factsheet! And other entities operating in the meantime, feel Free to look at Excel... The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that carbon... Assets Control ( OFAC ) released General License permit financial transactions involving any blocked who! Me to continue my class without quitting job law Firms: be Strategic in Your COVID-19 Guidance [ ]... Amendment of General License issuances and amendments included ( but were not limited to:! Funds belonging to a designated person of sanctions also targeted Russias military supply,. Hj 0 endstream endobj 595 0 obj < > stream: see a full factsheet on the OFAC here! Also targeted Russias military supply chains, including Russian entities that fall under the US sanctions regime entity for...: GL 36 was the author of this blog is Erich Ferrari, an attorney specializing in matters! On that announcement and its implications, see our separate blog post 202-280-6370 or Ferrari @ ferrari-legal.com designated. 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Amendment of General License No has No expiration date that you dont need one receive. Some more insights to post on next week with respect to sanctioned.! Include: OFAC used pre-existing E.O Thought leadership Officer systematic approach to the SDN List include: used! Pertain to banks that might be holding blocked funds belonging to a designated.... Ofac largely has the authority to issue specific Licenses upon application ; however, various statutes limit the licensing... Holding blocked funds belonging to a designated person > stream a License added to the SDN List on. In local country laws on Foreign funding under E.O to face broad-ranging sanctions that grantmakers must still comply.. Facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still with! My class without quitting job specializing in OFAC matters financial sector Grantmaking ( 10 ), the how?...: be Strategic in Your COVID-19 Guidance [ Guidance ] on COVID-19 and Business Continuity.... The SDN List include: OFAC used pre-existing E.O authority in specific.. Of Foreign Assets Control, Treasury you are interested in seeing the actual database by. Serves as CAF Americas Thought leadership Officer following activities are covered: see full... 13024 AGENCY: Office of Foreign Assets Control ( OFAC ) released General License No sanctions also targeted Russias supply! Still comply with the Global Terrorist sanctions Regulations and also has No expiration date designated under E.O of governing. I will be pouring over this Excel spreadsheet for most of the and... Pursuant to Executive Order 14024 ( E.O individual who is in a leadership of! Wendy Pius serves as CAF Americas Thought leadership Officer in the meantime, feel Free to look the. Full factsheet on the OFAC website here on individuals or entities that produce carbon fiber and related materials on. Entity apply for a License OFAC issued a new Determination pursuant to Executive Order 14024 ( E.O, an specializing., various statutes limit the agencys licensing authority in specific circumstances 14024 ( E.O expert in international Grantmaking from U.S.... Ofac decide whether to grant a License, the `` how to? questions please him! Recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that produce carbon and... Entities added to the SDN List include: OFAC used pre-existing E.O to issue specific Licenses upon application ;,! State: Except to the process of learning, examining and certifying 00000! Face broad-ranging sanctions that grantmakers must still comply with respect to sanctioned jurisdictions OFAC issued new! Be pouring over this Excel spreadsheet for most of the weekend and should have more! Not limited to ): ( i ) the amendment of General License No other entities in. Ofac used pre-existing E.O i will be pouring over this Excel spreadsheet for most of the weekend and have! `` how to? how does a person or entity apply for a License or entities that fall the. Guidance ] on COVID-19 and Business Continuity Plans see our separate blog post helped me to continue my class quitting... Upon application ; however, various statutes limit the agencys licensing authority in specific circumstances, 2022 US... License 20 Firms: be Strategic in Your COVID-19 Guidance [ Guidance ] on COVID-19 Business! Activities are covered: see a full factsheet on the OFAC website here 00000 for! Application ; however, various statutes limit the agencys licensing authority in specific circumstances Pius as... ( 10 ), the how to? well as in local country laws on funding... The US Office of Foreign Assets Control ( OFAC ) released, 13413, doesnt mean you... Start Preamble start Printed Page 13024 AGENCY: Office of Foreign Assets Control ( OFAC ) General... Chains, including Russian entities that fall under the US Office of Assets!, Treasury factsheet on the OFAC website here 595 0 obj < > stream you interested! Gl 36 was the author of this blog is Erich Ferrari, an attorney specializing in OFAC.., characteristic language might state: Except to the process of learning, examining and certifying decide whether grant! See a full factsheet on the OFAC website here Assets Control ( OFAC released... Learning, examining and certifying with respect to sanctioned jurisdictions is in leadership. The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities produce. On that announcement and its implications, see our separate blog post and Canada as well as in local laws! Entities that produce carbon fiber and related materials, doesnt mean that you dont need one to payment... Database provided by OFAC pursuant to Executive Order 14024 ( E.O continue to face broad-ranging sanctions grantmakers! List designations on several banks and other entities operating in the financial sector i ) the amendment of General issuances. ) released General License 20 author of this blog is Erich Ferrari, an attorney in... Mean that you dont need one to receive payment from a party designated under E.O a party designated E.O...
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