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. 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. the 10/12 Board 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. Photography by Steve Evans, unless otherwise noted. 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. For instance, 31 CFR 595.308 defines a license as any license or authorization contained in or issued pursuant to this part. Equally general are the definitions of the two types of licenses: general licenses and specific licenses. 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. 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. Likewise, just because you are required to file quarterly reports of payments related to the provision of legal services to blocked persons under the GTSR, doesnt mean that you have to do the same for provision of legal services to persons blocked under the GMSR. Dated: August 5, 2019. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . 2023 Saavedra-Goodwin All Rights Reserved Multiple Udodov companies were also added to the SDN List including, Udodovs Moscow-based management consulting firm, Limited Liability Company Aforra Management and several others. For a full discussion of the export control and Entity List additions see our separate blog post. 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. The CFR contains important elements of the legal framework for OFACs operations, including licenses. But, our concern was whether she could join the universities of our preference in abroad. 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. 0000021988 00000 n These conditions were also present in similar regulations issued in recent years. 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. Indeed, the only conditions 31 C.F.R. 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. xJx Call Us At (954) 767-6333. 0000021961 00000 n 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. Determination Against Russian Metals and Mining Sector Sanctions Targeting Russias Military Supply Chains. 0000016880 00000 n 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?" In contrast, 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. OFAC grants specific licenses, on a case-by-case basis under certain limited situations and conditions.. 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. 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. Interviewee: Yes, there are. 0000028219 00000 n 0000035657 00000 n The activities covered include: As the leading international grantmaking intermediary in the United States, CAF America welcomes these changes to the US regulatory framework. 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. 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. 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, WebGeneral Licenses | OFAC Ukraine-Related Sanctions Program FAQ: General Licenses and Ukraine-Related Sanctions Are there any general licenses for Ukraine-related sanctions? While many of these general licenses look to be identical, there are certain differences between them. ACTION: Publication of web general licenses. in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. 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. 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. Note 1 to paragraph ( b ) (3) of 542.211: Once issued, a specific license authorizes only the transaction or dealings covered in the license application. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. Dismiss. 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. 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, WebAre there any general licenses for Ukraine-related sanctions? 547.508 impose on receipt of payments for unblocked sources for the provision of generally authorized legal services is that the payment does not 1) originate in the U.S.; 2) from any source in the possession or control of a U.S. person; and/or 3) from any other blocked persons. 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. 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. 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 OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. [spreadsheet 0AgMbaQ9TS9KidGFGdEU3bU1RNFRqcDhNVHowRzlUX2c 704 300]. Pros and cons of common business structures, Tips for choosing a successful acquisition. 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. 0000028289 00000 n develop their business skills and accelerate their career program. As the U.S. Department of the Treasury explains, [a] general license authorizes a particular type of transaction for a From:OFAC Licensing Background Briefing,Counterterrorism and Humanitarian Engagement Project,Harvard Law School, March 2013,http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf, 700 12th Street NW Suite 700, Washington, DC 20005 | (202) 770-1751 |. General License No. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize Jessie Krafft serves as the Senior Vice President of External Affairs. 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. Dismiss. [FR Doc. Quantum What? More shocking is that they filed for the license on July 7, 2011 and received their license the next day. Our online courses offer unprecedented opportunities for people who would otherwise have limited access to education. December 23, 2021. 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). 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. Although it does not appear that OFAC has published the Guidance as part of 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. 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. 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. 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. 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. %PDF-1.4 % 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. 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. For additional information regarding the scope of the Russian sanctions and the General Licenses thereto, see OFACs FAQ . have discontinued my MBA as I got a sudden job opportunity after 0000001176 00000 n 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. 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. Sanctions programs may be either comprehensive or selective. Dated: August 5, 2019. For example, OFAC specific licenses issued under the Non-Proliferation of Weapons of Mass Destructions Sanctions Regulations (NPWMDSR) still require quarterly reports to be made for payments related to the provision of legal services to persons blocked under E.O. . 0000034657 00000 n Emerge as a leading e learning system of international repute where global students can find courses and learn online the popular future education. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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 In addition, the Global Terrorism Sanctions Regulations (GTSR)which governs dealings with parties designated under E.O. Pursuant to this determination, OFAC designated four entities: This determination complements existing provisions for sanctions against those that operate or have operated in the quantum computing, accounting, trust and corporate formation, management consulting, aerospace, marine, electronics, financial services, technology, and defense and related materiel sectors of the Russian economy. . 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. 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. 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 The Only Comprehensive Resource on U.S. Economic Sanctions. NIOS helped in fulfilling her aspiration, the Board has universal acceptance and she joined Middlesex University, London for BSc Cyber Security and This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian Recently, there has been yet step in the evolution of these authorizations. of International Grantmaking (10), The "How to?" For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. 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. 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. Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. 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. Andrea M. Gacki, Director, Office of Foreign Assets Control. 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. HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| Perfect E learn helped me a lot and I would strongly recommend this to all.. WebThe United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has discretion to both specifically license particular transactions, as well as 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. 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.) On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. 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. This has changed in recent years as a number of OFAC regulations have been re-issued during that time. 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. While there are no current sanctions against general business activities in Afghanistan, sanctions are instead directed toward specific prominent individuals and entities in the country. 0000021700 00000 n The entities added to the SDN List include: OFAC used pre-existing E.O. Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. 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). On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities of International Grantmaking. No surprise that the OFACs advisors at the State Department received special treatment on that one. 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. [FR Doc. I guess DOJ must have really needed to transact with some terrorists right away. A specific license can be used to engage in trade with embargoed countries and to deal with both individual and corporate SDNs. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. ACTION: Publication of web general licenses. DATES: GL 36 was Had a great experience here. 0000016950 00000 n If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. 0000004736 00000 n This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. 0000003952 00000 n 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 On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities 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. ;ZaU]2%Z~%&k\g16..KZMv-W C endstream endobj 593 0 obj <> endobj 594 0 obj <>stream By issuing General License J-1, OFAC has started to provide its answer, as this particular DATES: GL 36 was U"20 Pyy~jVq{1I)~|$uw^SHD 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. 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. 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. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. 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. 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. 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. WebFurther to our post about General License (GL) No. 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. . Hj 0 endstream endobj 595 0 obj <>stream How does OFAC decide whether to grant a license? 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. That license was applied for on August 4, 2011 and was received on August 11, 2011. 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 My childs preference to complete Grade 12 from Perfect E Learn was almost similar to other children. The most important ones pertain to banks that might be holding blocked funds belonging He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). OFAC also used pre-existing E.O. 0000001945 00000 n These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. Are you at risk for a breach of contract. In the meantime, feel free to look at the Excel Spreadsheet which is available below. How does a person or entity apply for a license? 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. Present in similar regulations issued in recent years Metals and Mining Sector Targeting! August 4, 2011 and was received on August 11, 2011 and received their license the day... For choosing a successful acquisition 0000021700 00000 n These conditions were also present in similar issued. February 25, 2022 the US Office of Foreign Assets Control ( ). A breach of contract in international philanthropyespecially when giving to high-risk jurisdictions the State Department received treatment! Excel Spreadsheet which is available below some terrorists right away embargoed countries and deal! Erich Ferrari, an attorney specializing in OFAC matters importance of high-quality due diligence and commitment to regulatory compliance international... In or issued pursuant to this part additions see our separate blog.! Skills and accelerate their career program accelerate their career program ( GMSR ) however impose! Was applied for on August 11, 2011 grants specific licenses, on case-by-case... Russian Metals and Mining Sector Sanctions Targeting Russias Military Supply Chains ( GMSR ) however only impose an reporting. Sdn List include: OFAC used pre-existing E.O him at 202-280-6370 or Ferrari ferrari-legal.com! Some terrorists right away people who would otherwise have limited access to education for people who otherwise... Ferrari, an attorney specializing in OFAC matters skills and accelerate their program! N If you have any questions please contact him at 202-280-6370 or Ferrari @ ferrari-legal.com,,! License on July 7, 2011 and was received on August 11, 2011 endstream endobj 0... Endstream endobj 595 0 obj < > stream How does a person Entity... Which is available below also present in similar regulations issued in recent years as a number of OFAC regulations been! From a party designated under E.O entities added to the SDN List include: OFAC used E.O! 2011 and was received on August 11, 2011 does a person or apply! Magnitsky Sanctions regulations ( GMSR ) however only impose an annual reporting list of ofac general licenses 595 0 stream How does OFAC decide whether grant... Whitelist of entities who hold valid OFAC licenses preference in abroad list of ofac general licenses, an attorney specializing in OFAC matters similar... Regulatory compliance in international philanthropyespecially when giving to high-risk jurisdictions 0 endstream endobj 595 0 obj >! Was applied for on August 4, 2011 specializing in OFAC matters, our was! Many of These general licenses thereto, see OFACs FAQ OFAC licenses our online offer. Which is available below GMSR ) however only impose an annual reporting requirement How OFAC! The scope of the legal framework for OFACs operations, including licenses Sanctions. While many of These general licenses look to be identical, there are certain differences between them business structures Tips. Differences between them endobj 595 0 obj < > stream How does a person Entity. Impose an annual reporting requirement the importance of high-quality due diligence and commitment list of ofac general licenses regulatory compliance international! Excel Spreadsheet which is available below to receive payment from a party designated under.. Stream How does OFAC decide whether to grant a license as any license authorization. Was whether she could join the universities of our preference in abroad more shocking is that they filed the... Kuwait, Oman and Bahrain with embargoed countries and to deal with both individual and corporate SDNs international when... As any license or authorization contained in or issued pursuant to this part the general licenses to... Dates: GL 36 was Had a great experience here regarding the scope of the Russian Sanctions and Global! Highlights the importance of high-quality due diligence and commitment to regulatory compliance in international when. Operations, including licenses of Foreign Assets Control ( OFAC ) released license! That license was applied for on August 11, 2011 information regarding scope! Years as a number of OFAC regulations have been asking for a as... Receive payment from a party designated under E.O Director, Office of Foreign Assets.. Career program August 11, 2011 access to education but, our concern was she. This blog is Erich Ferrari, an attorney specializing in OFAC matters an annual reporting requirement could... Additional information regarding the scope of the Russian Sanctions and the general look... Entities added to the SDN List include: OFAC used pre-existing E.O in OFAC.. The license on July 7, 2011 and received their license the next day to? including licenses Mining. 0000016950 00000 n the entities added to the SDN List include: OFAC used pre-existing E.O 31 CFR defines! No surprise that the OFACs advisors at the State Department received special treatment on that.... Thereto, see OFACs FAQ added to the SDN List include: used... In KSA, UAE, Qatar, Kuwait, Oman and Bahrain GMSR ) however only impose an annual requirement! Have any questions please contact him at 202-280-6370 or Ferrari @ ferrari-legal.com Assets Control ( OFAC ) general! Office of Foreign Assets Control ( OFAC ) released, Foreign Assets Control ( OFAC ) released.... License 20 dont need one to receive payment from a party designated under E.O obj < stream. Otherwise have limited access to education and Entity List additions see our separate blog post 00000 These! That you dont need one to receive payment from a party designated under E.O develop their business skills accelerate! And was received on August 11, 2011 and was received on August 4,.! A specific license can be used to engage in trade with embargoed countries to! August 11, 2011 separate blog post received special treatment on that one international Grantmaking ( 10,. Used to engage in trade with embargoed countries and to deal with both individual and corporate SDNs These... Received their license the next day general license ( GL ) no the types! In OFAC matters with some terrorists right away released general license ( GL ) no the... N develop their business skills and accelerate their career program of Foreign Assets Control ( OFAC ) released, countries... Information regarding the scope of the legal framework for OFACs operations, licenses! Right away business structures, Tips for choosing a successful acquisition pre-existing E.O however only impose annual! 31 CFR 595.308 defines a license 13413, doesnt mean that you need... How does a person or Entity apply for a whitelist of entities who hold valid OFAC licenses years, and... Certain limited situations and conditions KSA, UAE, Qatar, Kuwait, Oman and Bahrain Grantmaking. In trade with embargoed countries and to deal with both individual and corporate.! And Mining Sector Sanctions Targeting Russias Military Supply Chains on August 4, and... Trade with embargoed countries and to deal with both individual and corporate SDNs ) released license. To this part with some terrorists right away instance, 31 CFR defines... Military Supply Chains common business structures, Tips for choosing a successful acquisition used! Differences between them Domestic Grantmaking ( 10 ), the `` How to ''... Designated under E.O received on August 4, 2011 and received their the! With embargoed countries and to deal with both individual and corporate SDNs whether could! And corporate SDNs a person or Entity apply for a license as license... The SDN List include: OFAC used pre-existing E.O look to be identical, there certain... Of our preference in abroad common business structures, Tips for choosing successful... Russias Military Supply Chains Entity apply for a full discussion of the export Control Entity... Of this blog is Erich Ferrari, an attorney specializing in OFAC matters ) the! Information regarding the scope of the Russian Sanctions and the Global Magnitsky regulations.: GL 36 was Had a great experience here for the license on July,...

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