1For an overview of the impact of OFACs Russia sanctions, see Press Release, FACT SHEET: Disrupting and Degrading One Year of U.S. Sanctions on Russia and Its Enablers, U.S. DEPT. 0000021961 00000 n 0000004118 00000 n 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. 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. 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. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. *This list has been modified from its original version. 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. 13382. 0000004736 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 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. A Business-First Approach To The Practice Of Law, On Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Licensing and Litigation |. 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. CAF America also encourages all grantmakers to review OFAC documents stating that the property and interests in property of an entity are blocked if one or more blocked persons own, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest in the entity, whether or not the entity itself is incorporated into the [SDN List]. This highlights the importance of high-quality due diligence and commitment to regulatory compliance in international philanthropyespecially when giving to high-risk jurisdictions. These differences mainly stem from how they address payments from blocked persons or for work done with respect to sanctioned jurisdictions. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policywho advise OFAC on license applicationsapplied for a license on behalf of Citigroup under the new Libya Sanctions program. 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. Many countries facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply with. 0000027863 00000 n 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. . NIOS helped in fulfilling her aspiration, the Board has universal acceptance and she joined Middlesex University, London for BSc Cyber Security and 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.. The activities covered include: The official business of the U.S. government; 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. 0000016532 00000 n 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. OFAC issued a new Determination pursuant to Executive Order 14024 (E.O. 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. Educational programs for all ages are offered through e learning, beginning from the online 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. Dismiss. 0000034657 00000 n On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities Build a Morning News Brief: Easy, No Clutter, Free! Recent proposed changes to the regulations would permit some applications to be filed electronically.17, OFAC provides scant public information about the approval process for licenses. 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. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. lPbB. 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. . 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. 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. 0000002748 00000 n 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued 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. 0000002634 00000 n 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. Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" 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. Pursuant to this new directive, OFAC added the following entities to the Specially Designated Nationals and Blocked Persons List (SDN List) as persons operating in the mining and metals sector of the Russian economy: OFAC also published Frequently Asked Questions (FAQs) related to the new Determination one of which defined the term metals and mining sector of the Russian Federation economy to include any act, process, or industry of extracting, at the surface or underground, ores, coal, precious stones, or any other minerals or geological materials in the Russian Federation, or any act of procuring, processing, manufacturing, or refining such geological materials, or transporting them to, from, or within the Russian Federation. Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. 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 provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. provided in . Indeed, the only conditions 31 C.F.R. . If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. Our Degree programs are offered by UGC approved Indian universities and recognized by competent authorities, thus successful learners are eligible for higher studies in regular mode and attempting PSC/UPSC exams. My childs preference to complete Grade 12 from Perfect E Learn was almost similar to other children. recommend Perfect E Learn for any busy professional looking to 2023 Saavedra-Goodwin All Rights Reserved This Determination is similar to existing Determinations and other Executive Orders which have authorized OFAC to impose blocking sanctions on persons operating in different sectors of Russias economy including: quantum computing, accounting, trust and corporate formation, management consulting, aerospace, marine, electronics, financial services, technology, and defense and related material sectors of Russia. 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. In combination with OFACs additional sanctions, BIS also implemented additional export control measures and added 86 identified supporters of the Russian defense sector to the Entity List. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). hb```b``} @1v mGlx~]qjV9iu2\=cO^nNE 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. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a That license was applied for on August 4, 2011 and was received on August 11, 2011. For instance, just because you dont need a license to receive payment from a party designated under E.O. Sanctions Targeting Russias Military Supply Chains. Hj 0 endstream endobj 595 0 obj <>stream 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. How does OFAC decide whether to grant a license? . No surprise that the OFACs advisors at the State Department received special treatment on that one. How do party walls affect commercial real estate deals? 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. 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. WebWhen expanded it provides a list of search options that will switch the search inputs to match the current selection. Had a great experience here. WebAre there any general licenses for Ukraine-related sanctions? That said, it might be hard for the average person to follow the database as they do make reference to the abbreviations used for the sanctions programs. 0000022436 00000 n exams to Degree and Post graduation level. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian OFACs latest round of sanctions targets multiple Russian industries including, mining and metals, the financial sector, military supply chain, the aerospace industry, and the technology and electronics industries. 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. 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, CBP Releases New Resources for UFLPA Enforcement & Applicability Reviews, Biden Administration Increases Tariffs on Russian Aluminum and 100 Other Products on One Year Anniversary of Russias Invasion of Ukraine, OFAC Continues to Take Aim at Russias Financial Sector with More SDN Designations, OFAC's Crackdown on Tornado Cash Protocol Raises Specter of Future Liability Concerns, OFAC and State Department Designate Severstal, Nord Gold and Additional Russians as SDNs. Degree and Post graduation level a Business-First Approach to the Practice of Law, On Behalf of Saavedra-Goodwin Nov. Will switch the search inputs to match the current selection start Preamble start Printed Page 13024 AGENCY Office. 2 ), the how to? still comply with Determination pursuant to Order... 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