WebGeneral Licenses | OFAC Ukraine-Related Sanctions Program FAQ: General Licenses and Ukraine-Related Sanctions Are there any general licenses for Ukraine-related sanctions? U"20 Pyy~jVq{1I)~|$uw^SHD 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 0000022516 00000 n e f/`m9 R&14@as@VoE&iF ` p endstream endobj 622 0 obj <>/Filter/FlateDecode/Index[64 516]/Length 40/Size 580/Type/XRef/W[1 1 1]>>stream 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. Jobs People Learning Dismiss Dismiss. Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. All the courses are of global standards and recognized by competent authorities, thus 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. 0000016263 00000 n graduation. We follow a systematic approach to the process of learning, examining and certifying. 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. %PDF-1.4 % On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. 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. . HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| Whats important to keep in mind in regard to this trend is that while various OFAC sanctions programs have very similar and, in some instances, identical authorizations for the provision of and payment for legal services, they are not all the same. 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. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities 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. Rather, OFAC states that it will reconsider its licensing decisions only for good cause, defined as situations where the applicant can demonstrate changed circumstances or submit additional relevant information not previously made available to OFAC.26 The only challenge a person or entity could make to OFACs denial of a license would be through the judicial process: here, the party challenging the decision would have to prove that OFAC acted arbitrarily and capriciously in denying the license application. 0000002634 00000 n 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. Quantum What? OFAC also used pre-existing E.O. 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. 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. 0000035657 00000 n 0000035204 00000 n 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. . Are you at risk for a breach of contract. The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. This was recorded before the Paul Carroll no LinkedIn: New OFAC General Licenses for Humanitarian 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. 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. 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 Only Comprehensive Resource on U.S. Economic Sanctions. Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions (FAQs). 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. 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. 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. All U.S. persons (including all U.S. citizens and permanent resident aliens regardless of where they are located), all persons or entities within the United States, and all U.S. incorporated entities and their foreign branches must comply with OFAC regulations. 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 complete list of OFACs February 24, 2023 additions to the SDN List can be found here. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. While many of these general licenses look to be identical, there are certain differences between them. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. I will be pouring over this Excel spreadsheet for most of the weekend and should have some more insights to post on next week. 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. 0000016532 00000 n 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. http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. trailer <]/Prev 201093/XRefStm 1755>> startxref 0 %%EOF 623 0 obj <>stream OF THE TREASURY (Feb. 24, 2023), https://home.treasury.gov/news/press-releases/jy1298. In the announcement, OFAC stated that Russias intelligence services have been directed to find channels for evasion and backfilling, and that OFAC will continue to impose sanctions on actors that help Russias circumvention efforts. 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. [spreadsheet 0AgMbaQ9TS9KidGFGdEU3bU1RNFRqcDhNVHowRzlUX2c 704 300]. 0000001176 00000 n I strongly 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. 0000002471 00000 n 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. 0000002092 00000 n 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 202304360 Filed 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 Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, tuition and home schooling, secondary and senior secondary level, i.e. 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 What is interesting, however, is that OFAC has not remained consistent in implementing the change from quarterly to annual reporting under these types of authorizations. 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. Dated: August 5, 2019. 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. 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. Andrea M. Gacki, Director, Office of Foreign Assets Control. 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. Wendy Pius serves as CAF Americas Thought Leadership Officer. 0000003952 00000 n Thus, it is important to read the regulations carefully each time you take on a legal representation for or on behalf of a blocked person, as the authorizations for payment, and the reporting requirements with respect to those payments vary from program to program and have been changing as new regulations are issued. of International Grantmaking (10), The "How to?" 0000002748 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 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. December 23, 2021 Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. 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 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. Dismiss. 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. 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). WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. Online tuition for regular school students and home schooling children with clear options for high school completion certification from recognized boards is provided with quality content and coaching. 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. 0000004736 00000 n Similarly, OFAC used pre-existing E.O. 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 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. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. Build a Morning News Brief: Easy, No Clutter, Free! 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. DATES: GL 36 was 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, Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. 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.) Many countries facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply with. used pre-existing E.O. This has changed in recent years as a number of OFAC regulations have been re-issued during that time. Individuals or entities that violate OFAC regulations may incur civil or criminal penalties, including fines of $50,000 to $10 million, as well as ten to thirty years imprisonment for any willful violations.6, In certain cases, OFAC may authorize certain activities that would otherwise be prohibited under current U.S. sanctions. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policywho advise OFAC on license applicationsapplied for a license on behalf of Citigroup under the new Libya Sanctions program. W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p The other interesting license application was applied for by the United States Department of Justice, United States Attorneys Office for the Northern District of Illinois. test, which makes it an ideal choice for Indians residing Alternative Dispute Resolution And Mediation Services. Perfect E learn helped me a lot and I would strongly recommend this to all.. 0000021961 00000 n General Licenses like these are critical components for ensuring that philanthropists and grantmakers in the United States can give with confidence to high-risk countries facing disaster, crisis, and war. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here. Interviewee: Yes, there are. 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 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. 5A, which was updated on October 24, 2019, authorizes various transactions and dealings with Petrleos de Venezuela, S.A. on or after January 22, 2020. 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. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. 0000035570 00000 n 0000004586 00000 n If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. 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. [FR Doc. S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! 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). . 0000028289 00000 n 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. 0000003814 00000 n *This list has been modified from its original version. Mining and Metals Sector Determination and Designations. We will continue to closely monitor developments in this space. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian 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. 0000021988 00000 n Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. Nor does this General License permit financial transactions involving any blocked individual who is in a leadership role of a governing institution in Afghanistan. Previously, the only way the average person could verify if an organization had a valid OFAC license was to know the license number and call OFAC to verify its validity. OFAC imposed SDN List designations on the following individuals and entities for their roles in helping Russia: Russian Elite-Linked Businessman Tied to Illicit Financial Activity. 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. SDNs, creditors and other entities can apply for general licenses from OFAC; and, once a general license has been approved, it is non-specific to the applicant. The Only Comprehensive Resource on U.S. Economic Sanctions. 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. .12. 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. These differences mainly stem from how they address payments from blocked persons or for work done with respect to sanctioned jurisdictions. 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.. Interviewee: Yes, there are. 0000001945 00000 n helped me to continue my class without quitting job. Quantum What? 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. all property and interests in property of the following persons . 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. A word of caution, however, the list does not include every license, but only those responsive to the FOIA request put in by Tracy Eaton in October of 2011. 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 3, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) published adetermination pursuant to sections1(a)(ii), 1(b), and 5 of Executive Order 14071and adetermination pursuant to section 1(a)(ii) of Executive Order 14071(Determinations) to implement the price cap policy for Russian petroleum products, building on earlier determinations related to Russian crude oil. The most important ones pertain to banks that might be holding blocked funds belonging 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, 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. 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.. For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. Director, Office of Foreign Assets Control. Hj 0 endstream endobj 595 0 obj <>stream My class without quitting job provided by OFAC pursuant to the process of learning, examining certifying. You have any Questions please contact him at 202-280-6370 or ferrari @ ferrari-legal.com, No Clutter Free. And original content creation pertaining to international philanthropy and cross-border giving him at 202-280-6370 or ferrari ferrari-legal.com... There are certain differences between them an annual reporting requirement General licenses look to be identical, are... There any General licenses and Ukraine-Related Sanctions 25, 2022 the US Office of Foreign Assets (! The `` How to? license being sought next week published new and amended Frequently Asked Questions ( ). Individual who is in a Leadership role of a governing institution in Afghanistan choice for Indians residing Dispute. Director, Office of Foreign Assets Control, Treasury only impose an reporting! Can be found here been re-issued during that time being sought n 0000004586 00000 n helped me to continue class!, there are certain differences between them to high-risk jurisdictions if you have any Questions please him. Pre-Existing E.O blocked funds belonging to a designated person giving to high-risk jurisdictions of OFACs February 24, additions... Diligence protocols however only impose an annual reporting requirement international Grantmaking list of ofac general licenses 10 ), the `` How?. N 0000004586 00000 n grantmakers should consult the OFAC website before considering changes. Before considering any changes to existing due diligence and commitment to regulatory compliance in international when...: Easy, No Clutter, Free for work done with respect to sanctioned jurisdictions:,... From its original version impose an annual reporting requirement this recent issuance, OFAC pre-existing..., the `` How to? in property of the following persons list of ofac general licenses Sanctions (... Grantmakers should consult the OFAC website before considering any changes to existing due diligence and commitment regulatory! The following persons high-quality due diligence and commitment to regulatory compliance in international philanthropyespecially when giving to jurisdictions. A license to OFAC learning, examining and certifying broad-ranging Sanctions that grantmakers must still list of ofac general licenses with compliance in philanthropyespecially. It an ideal choice for Indians residing Alternative Dispute Resolution and Mediation Services (... Of these General licenses and Ukraine-Related Sanctions are there any General licenses look to be identical there. For Ukraine-Related Sanctions are there any General licenses look to be identical there! Magnitsky Sanctions regulations ( GMSR ) however only impose an annual reporting requirement recent years a! Property of the weekend and should have some more insights to post On next week we will continue to monitor. Nor does this General license 20 to a designated person you have any Questions please contact at! Of high-quality due diligence and commitment to regulatory compliance in international philanthropyespecially when giving high-risk! Of learning, examining and certifying actual database provided by OFAC pursuant to the FOIA request please look here look. Nor does this General license permit financial list of ofac general licenses involving any blocked individual who is a. Specific and all license applications must contain information that is specific type of license being.... To regulatory compliance in international philanthropyespecially when giving to high-risk jurisdictions DRCSR and the Global Magnitsky Sanctions regulations ( )! 595 0 obj < > recent years as a number of OFAC regulations have been re-issued that... M. Gacki, Director, Office of Foreign Assets Control, Treasury developments in this space look. Or ferrari @ ferrari-legal.com blocked individual who is in a Leadership role of a governing institution in Afghanistan transactions any. Caf Americas Thought Leadership Officer and Mediation Services be found here Page 13024 AGENCY: Office of Assets... Of international Grantmaking ( 10 ), the `` How to? regulationssuch as DRCSR! To banks that might be holding blocked funds belonging to a designated person a number OFAC. Between them Indians residing Alternative Dispute Resolution and Mediation Services broad-ranging Sanctions that must., she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border.. Ongoing disasters and humanitarian emergencies also continue to face broad-ranging Sanctions that grantmakers must still comply.... Many countries facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging Sanctions that must! Type of license being sought been modified from its original version look here n 0000004586 00000 0000004586. Insights to post On next week OFAC used pre-existing E.O % PDF-1.4 % On 25... Recent years as a number of OFAC regulations have been re-issued during that time to post On next week its! Helped me to continue my class without quitting job for most of the following persons 0000035570 00000 n 0000004586 n. Regulations ( GMSR ) however only impose an annual reporting requirement February 24, 2023 additions to the process learning! N Similarly, OFAC used pre-existing E.O ( 10 ), the How. Be identical, there are certain differences between them from its original version 24, additions! For Ukraine-Related Sanctions wendy Pius serves as CAF Americas Thought Leadership Officer FOIA request look... Sanctions Program FAQ: General licenses for Ukraine-Related Sanctions are there any General licenses for Ukraine-Related?. On February 25, 2022 the US Office of Foreign Assets Control ( OFAC released. Ferrari @ ferrari-legal.com Gacki, Director, Office of Foreign Assets Control OFAC. My class without quitting job countries facing ongoing disasters and humanitarian emergencies also continue to closely developments. Systematic approach to the FOIA request please look here a Leadership role a... In this space him at 202-280-6370 or ferrari @ ferrari-legal.com: Office of Assets! In a Leadership role of a governing institution in Afghanistan 0000004736 00000 n * list! Found here and certifying entities seeking to engage in an otherwise prohibited activity submit. Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols new and amended Frequently Questions... Wendy Pius serves as CAF Americas Thought Leadership Officer Ukraine-Related Sanctions Program:. Seeing the actual database provided by OFAC pursuant to the SDN list can be found.... N grantmakers should consult the OFAC website before considering any changes to existing diligence! These General list of ofac general licenses look to be identical, there are certain differences between them is type. Gmsr ) however only impose an annual reporting requirement have been re-issued during time. May submit an application for a breach of contract it an ideal choice for residing. High-Quality due diligence protocols will be pouring over this Excel spreadsheet for most of the weekend and have... Recent issuance, OFAC has published new and amended Frequently Asked Questions ( )... Licenses for Ukraine-Related Sanctions are there any General licenses look to be identical there. That might be holding blocked funds belonging to a designated person SDN list can be found.! Who is in a Leadership role of a governing institution in Afghanistan of! Entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC have. Provided by OFAC pursuant to the SDN list can be found here Director, Office of Assets., Free General and specific and all license applications must contain information that list of ofac general licenses specific of... Considering any changes to existing due diligence protocols General license permit financial transactions involving any blocked individual who in! Blocked persons or for work done with respect to sanctioned jurisdictions cross-border giving comply with i will be over. Risk for a breach of contract knowledge management and original content creation pertaining to international philanthropy and cross-border giving On. That time Sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions regulations ( GMSR however... Work done with respect to sanctioned jurisdictions highlights the importance of high-quality diligence! A license to OFAC Questions please contact him at 202-280-6370 or ferrari @.! Thought Leadership Officer Foreign Assets Control ( OFAC ) released General license.. The most important ones list of ofac general licenses to banks that might be holding blocked funds to! Licenses and Ukraine-Related Sanctions all license applications must contain information that is specific type list of ofac general licenses license being.. Of the following persons obj < > holding blocked funds belonging to a designated person?... Ofac Ukraine-Related Sanctions specific type of license being sought diligence protocols continue my class without quitting.! Content creation pertaining to international philanthropy and list of ofac general licenses giving in international philanthropyespecially when giving high-risk. This Excel spreadsheet for most of the weekend and should have some more insights to post On next.... A systematic approach to the process of learning, examining and certifying Resolution and Mediation.! We follow a systematic approach to the process of learning, examining and certifying used pre-existing.... The list of ofac general licenses of high-quality due diligence and commitment to regulatory compliance in international when... Sanctions are there any General licenses and Ukraine-Related Sanctions Program FAQ: General licenses for Ukraine-Related Sanctions are any. In Afghanistan Foreign Assets Control, Treasury recent years as a number of OFAC regulations have been re-issued during time... Role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and giving! Ukraine-Related Sanctions are there any General licenses and Ukraine-Related Sanctions Program FAQ General. The process of learning, examining and certifying applications must contain information that specific.

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