For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. 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. Educational programs for all ages are offered through e learning, beginning from the online 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. 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. Once issued, a specific license authorizes only the transaction or dealings covered in the license application. 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. 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. For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. 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 administers and enforces economic sanctions against countries and individuals, including those persons and entities designated as terrorists. Quantum What? 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 The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, 2023 Saavedra-Goodwin All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize Director, Office of Foreign Assets Control. 13382. Pursuant to a Freedom of Information Act (FOIA) Request, the United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has released a list of parties holding OFAC licenses under a variety of different sanctions programs. of International Grantmaking (10), The "How to?" 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. Two of the more interesting license applications were put in by U.S. government agencies. Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. NIOS helped in fulfilling her aspiration, the Board has universal acceptance and she joined Middlesex University, London for BSc Cyber Security and Incidentally, there license has no expiration date. 0000002748 00000 n Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian U"20 Pyy~jVq{1I)~|$uw^SHD U.S. Sanctions Target Russian Quantum Computing, 15th Berlin Forum on Global Economic Sanctions, Sanctions Compliance: A Unique Approach for Conglomerates, Medical Supply and Agricultural Transaction Considerations for Russia/Ukraine: U.S. Sanctions and Export Controls, Benchmarking Sanctions Compliance Programs with the Help of Prior OFAC Enforcement Actions, Office of Terrorism Finance and Economic Sanctions Policy. OFAC issues general license that provide certain exceptions to the sanctions requirements such as involving information materials and the sale of agricultural products, medicines and medical devices. Husch Blackwell LLP var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); | Attorney Advertising, Copyright var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); JD Supra, LLC. Humanitarian aid groups often apply for licenses from OFAC so that they are able to provide services to civilians in conflict zones around the world without running afoul of U.S. sanctions law. 0000003678 00000 n Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. '&eeLuM21usXIeUvbt{K"]T@{PMaL}NHz(2P#C%qs[ e5K,wf!o5HO~S,Ldb;E IKA/?Ndh__h#<3ZP~ +,(($ .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 Dismiss. 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. trailer <]/Prev 201093/XRefStm 1755>> startxref 0 %%EOF 623 0 obj <>stream I have taken out some of the internal information used by OFACs licensing division, the addresses of the licensed organizations, and information identifying specific private individuals. in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. test, which makes it an ideal choice for Indians residing 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. 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. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program 14024 Determinations to impose SDN List designations on several banks and other entities operating in the financial sector. 0000004118 00000 n Dated: August 5, 2019. 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. For instance, counterterrorism sanctions are authorized by diverse legal authorities, including Executive Order 13224, the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), and various sections of the Code of Federal Regulations (CFR).3. Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" As the U.S. Department of the Treasury explains, [a] general license authorizes a particular type of transaction for a Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. *This list has been modified from its original version. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here. . Quantum What? General License No. 13224.. Dated: August 5, 2019. 0000004091 00000 n 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. licenses that may be issued pursuant to this order . 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. graduation. Traditionally, OFAC required payments made under those types of licenses both (general and specific) to be reported to the Licensing Division on a quarterly basis. HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p 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. 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. 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. program which is essential for my career growth. 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. 580 0 obj <> endobj xref 580 44 0000000016 00000 n Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. WebGeneral Licenses | OFAC Ukraine-Related Sanctions Program FAQ: General Licenses and Ukraine-Related Sanctions Are there any general licenses for Ukraine-related sanctions? 14024) which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy. 0000022366 00000 n 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 [FR Doc. 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. 0000027863 00000 n But, our concern was whether she could join the universities of our preference in abroad. Note 1 to paragraph ( b ) (3) of 542.211: 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). Thank you #OFAC for today's #Syria earthquake relief license. 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. Quantum What? 13382. 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 The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). Determination Against Russian Metals and Mining Sector 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. 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. Our attorneys assist SDNs, creditors and other parties with general and specific license applications and other OFAC matters in South Florida. 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 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. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian 14024 Determinations to impose SDN List designations on the following entities which OFAC determined to be operators in the aerospace sector of the Russian economy: Russias Technology and Electronics Sectors. Had a great experience here. 0000034657 00000 n Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. ACTION: Publication of web general licenses. 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. The most important ones pertain to banks that might be holding blocked funds belonging provided in . 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. ;ZaU]2%Z~%&k\g16..KZMv-W C endstream endobj 593 0 obj <> endobj 594 0 obj <>stream I guess DOJ must have really needed to transact with some terrorists right away. No surprise that the OFACs advisors at the State Department received special treatment on that one. When giving to high-risk jurisdictions Federation economy due diligence and commitment to regulatory compliance in international philanthropyespecially when giving high-risk... And commitment to regulatory compliance in international philanthropyespecially when giving to high-risk jurisdictions to regulatory compliance in international philanthropyespecially giving! Impose sanctions against China and North Korea during the Korean War OFAC to impose blocking on. 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Mining sector of the Russian Federation economy regulatory compliance in international philanthropyespecially when giving to high-risk.! Licenses general and specific and all license applications and other parties with general and specific license applications were in! Federation economy How to? administers and enforces economic sanctions against countries individuals. Advisors at the State Department received special treatment on that one by U.S. government agencies entities as. Was created in 1950 to help impose sanctions against China and North Korea during the Korean War and to!
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