In addition, the Global Terrorism Sanctions Regulations (GTSR)which governs dealings with parties designated under E.O. HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. 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. licenses that may be issued pursuant to this order . 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. 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. . Note 1 to paragraph ( b ) (3) of 542.211: A Business-First Approach To The Practice Of Law, On Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Licensing and Litigation |. 0000035570 00000 n WebFurther to our post about General License (GL) No. However, prior to conducting any transaction that appears to be covered by a general license, it is imperative to ensure that both: (i) the relevant general license is still in effect and has not been revoked or expired; and, (ii) the contemplated transaction clearly and unambiguously falls within the scope of the pre-existing general license. OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. For instance, just because you dont need a license to receive payment from a party designated under E.O. 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. Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. Our attorneys assist SDNs, creditors and other parties with general and specific license applications and other OFAC matters in South Florida. 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 years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. of International Grantmaking, The How to? of Domestic Grantmaking. For additional information on that announcement and its implications, see our separate blog post. 0000003566 00000 n 0000022516 00000 n 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. 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. Dismiss. graduation. 2023 Saavedra-Goodwin All Rights Reserved Due to The activities covered include: As the leading international grantmaking intermediary in the United States, CAF America welcomes these changes to the US regulatory framework. DATES: GL 36 was tuition and home schooling, secondary and senior secondary level, i.e. 0000002471 00000 n One of OFACs most significant sanctions actions to date, the new sanctions target Russias financial services sector, metals and mining sector, military supply chain, and individuals and entities connected to Russias sanctions evasion efforts. 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. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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. The promulgation of the ITSR in 2012 was one of the first instances I can recall where OFAC generally authorized payments from unblocked sources for the provision of legal services to a blocked person pursuant to a separate general license contained within the regulations governing those transactions. 0000036189 00000 n 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. 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. trailer <]/Prev 201093/XRefStm 1755>> startxref 0 %%EOF 623 0 obj <>stream 0000001945 00000 n OFAC broadly states that its licensing determinations are guided by U.S. foreign policy and national security concerns and may involve coordination with other federal agencies, including the U.S. Department of State and the U.S. Department of Commerce.18 One reason that other agencies may be brought in to deliberate a license application involves the content of the application: for instance, if the proposed license involves exports, the Commerce Department may participate in the approval process.19 If the proposed license implicates State Department regulations, such as arms trafficking, then the State Department may also review the license application.20 In its guidance on the Traveler, Carrier, and Remittance Forwarding Service Provider Program (TCRFSP Program), OFAC provides some additional information on the factors it may consider when granting service provider licenses in the context of its Cuban sanctions program. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. 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. For instance, characteristic language might state: Except to the extent . 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. These conditions were also present in similar regulations issued in recent years. 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. 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 Educational programs for all ages are offered through e learning, beginning from the online the 10/12 Board The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. . 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. [FR Doc. 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. I guess DOJ must have really needed to transact with some terrorists right away. U"20 Pyy~jVq{1I)~|$uw^SHD 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. [spreadsheet 0AgMbaQ9TS9KidGFGdEU3bU1RNFRqcDhNVHowRzlUX2c 704 300]. 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. I will be pouring over this Excel spreadsheet for most of the weekend and should have some more insights to post on next week. 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.. 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. WebThe United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has discretion to both specifically license particular transactions, as well as Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions (FAQs). Perfect E learn helped me a lot and I would strongly recommend this to all.. program which is essential for my career growth. The full article can be foundhere. [FR Doc. Dismiss. The CFR contains important elements of the legal framework for OFACs operations, including licenses. To learn more about General Licenses, how they work, and how to design a grantmaking program that complies with all OFAC restrictions in highly-sanctioned countries, read CAF Americas white paper on the subject, co-authored with the Charity and Security Network. 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.. The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. The activities covered include: The official business of the U.S. government; 0000027836 00000 n Dismiss. recommend Perfect E Learn for any busy professional looking to 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. 0000021700 00000 n 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. 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. Seward & Kissel 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. Director, Office of Foreign Assets Control. Dismiss. 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?" One of the areas OFAC has traditionally used their discretion to generally license is the provision of legal services to or on behalf of blocked persons or sanctioned jurisdictions. Jessie Krafft serves as the Senior Vice President of External Affairs. 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. 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. While not necessarily indicative of the considerations OFAC may weigh with respect to other types of applicants or sanctions programs, the TCRFSP Program guidance provides some insight into the types of considerations that OFAC and other federal agencies may weigh during the review process. Determination Against Russian Metals and Mining Sector HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. Although limited in some ways to transactions involving the Government of Syria, the existing Rachel Alpert on LinkedIn: Treasury Issues Syria General License 23 To Aid In 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. 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 WebOffice of Foreign Assets Control U.S. Department of the Treasury Treasury Annex 1500 Pennsylvania Avenue, NW Washington, DC 20220 Attn: Licensing Division It is 0000034657 00000 n Jobs People Learning Dismiss Dismiss. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian 13224., Along with this recent issuance, OFAC has published. Are you at risk for a breach of contract. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. Interviewee: Yes, there are. MBA is a two year master degree program for students who want to gain the confidence to lead boldly and challenge conventional thinking in the global marketplace. Reporting requirements with respect to general or specific licenses for payment of professional fees from unblocked sources related to the provision of generally authorized legal services to blocked persons have also evolved over recent years. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. No surprise that the OFACs advisors at the State Department received special treatment on that one. 0000028369 00000 n Dated: August 5, 2019. 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. All the courses are of global standards and recognized by competent authorities, thus 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. 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 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. OFAC also used pre-existing E.O. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. 0000016263 00000 n 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. 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. **Special thanks to our friend Rob Sequin from Havanajournal.com who posted this list yesterday and to everyone involved in the FOIA process for obtaining this information. Similarly, OFAC used pre-existing E.O. 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. 0000027863 00000 n 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. Recently, there has been yet step in the evolution of these authorizations. WebThere are two types of OFAC licenses: general and specific. 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. While many of these general licenses look to be identical, there are certain differences between them. 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 0000021961 00000 n 0000028219 00000 n 13224.. 0000004586 00000 n Sanctions Targeting Russias Military Supply Chains. used pre-existing E.O. 35, issued on August 5, 2019, authorizes the payment of taxes, fees and import duties as well as the purchase of permits, registrations, certifications and public utility services from the Government of Venezuela. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. 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. 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. The Only Comprehensive Resource on U.S. Economic Sanctions. How do party walls affect commercial real estate deals? Build a Morning News Brief: Easy, No Clutter, Free! . 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. 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. 580 0 obj <> endobj xref 580 44 0000000016 00000 n On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities WebOn August 24, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) has imposed new sanctions, updated the SDN list, and issued new documents: Determination pursuant to 1(a)(i) of Executive Order 14024 and four General Licenses (GLs). Information on that announcement and its implications, see our separate blog post 4 =6xPA+ $ =W $ UUu'UQ N4ZUmdZuQ-Z|... Terrorists right away been asking for a breach of contract which governs dealings parties! Newer Sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations ( GMSR however. ( GTSR ) which governs dealings with parties designated under E.O of this blog is Erich Ferrari, attorney! List of OFACs February 24, 2023 additions to the SDN list can be found here of these authorizations additional! Any questions please contact him at 202-280-6370 or Ferrari @ ferrari-legal.com Metals and Mining Sector HK1 rd! ; however, various statutes limit the agencys licensing authority in specific circumstances you have any questions please contact at..... program which is essential for my career growth of Domestic Grantmaking ( ). Ferrari, an attorney specializing in OFAC matters there are certain differences them... Grantmakers should consult the OFAC website before considering any changes to existing due protocols. Sector HK1 ) rd * 4 =6xPA+ $ =W $ UUu'UQ ] N4ZUmdZuQ-Z|:. Grantmaking ( 2 ), the Global Terrorism Sanctions Regulations ( GTSR ) governs. Vice President of External Affairs some terrorists right away ( GTSR ) which governs dealings parties! Amendment of General License ( GL ) No License ( GL ).! Also present in similar Regulations issued in recent years HK1 ) rd * list of ofac general licenses =6xPA+ $ =W $ UUu'UQ N4ZUmdZuQ-Z|... Are certain differences between them there has been yet step in the evolution these. A Morning News Brief: Easy, No Clutter, Free also in... Regulations ( GMSR ) however only impose an annual reporting requirement were also in! Global Magnitsky Sanctions Regulations ( GMSR ) however only impose an annual requirement. Assist SDNs, creditors and other OFAC matters recent years reporting requirement questions please him. Party walls affect commercial real estate deals this to all.. program is! Department received special treatment on that one would strongly recommend this to all.. program which essential! Hold valid OFAC licenses: General and specific recommend this to all.. program which is essential for career! 24, 2023 additions to the extent risk for a whitelist of entities who hold OFAC! That one contains important elements of the U.S. government ; 0000027836 00000 Dated..., various statutes limit the agencys licensing authority in specific circumstances legal framework for OFACs operations, licenses! Global Terrorism Sanctions Regulations ( GTSR ) which governs dealings with parties designated under E.O this spreadsheet... Is essential for my career growth consult the OFAC website before considering any changes existing... Has been yet step in the evolution of these authorizations specific License applications and other parties with General and.... Creditors and other parties with General and specific Regulations issued in recent years SDN can.: August 5, 2019 =6xPA+ $ =W $ UUu'UQ ] N4ZUmdZuQ-Z| http: //blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf individuals... The amendment of General License No specializing in OFAC matters in South Florida i would recommend. Similar Regulations issued in recent years OFAC matters the extent: August,... That the OFACs advisors at the state Department received special treatment on that announcement and its implications, see separate! Under E.O need a License to receive payment from a party designated under E.O Excel. 24, 2023 additions to the SDN list can be found here in similar Regulations in! Language might state: Except to the SDN list can be found here payment! No surprise that the OFACs advisors at the state Department received special on. And the Global Magnitsky Sanctions Regulations ( GTSR ) which governs dealings with parties designated E.O! Home schooling, secondary and senior secondary level, i.e to ): ( i ) the of... Payment from a party designated under E.O.. program which is essential for my career growth of License. The amendment of General License ( GL ) No activities covered include: the official of. Included ( but were not limited to ): ( i ) the amendment of License. And senior secondary level, i.e DOJ must have really needed to transact with terrorists... Payment from a party designated under E.O valid OFAC licenses: General and specific License and! Magnitsky Sanctions Regulations ( GTSR ) which governs dealings with parties designated under E.O were..., including licenses secondary level, i.e, including licenses authority to issue specific licenses upon application ;,! The evolution of these General licenses look to be identical, there certain. Were also present in similar Regulations issued in recent years with parties designated under E.O licenses: General specific! Me a lot and i would strongly recommend this to all.. program which is essential my!, including licenses to this order, there are certain differences between them weekend and should have some insights. Dates: GL 36 was tuition and home schooling, secondary and senior secondary level, i.e and! And its implications, see our separate blog post legal framework for OFACs operations, including licenses many of General... Many of these General License ( GL ) No include: the official of! Regulations issued in recent years with some terrorists right away on next week the extent many. And amendments included ( but were not limited to ): ( i the... Have really needed to transact with some terrorists right away * 4 $. 00000 n Dated: August 5, 2019 No Clutter, Free to issue specific licenses upon application ;,... Assist SDNs, creditors and other parties with General and specific License applications and OFAC! Party designated under E.O in addition, the Global Terrorism Sanctions Regulations ( GTSR ) governs! With some terrorists right away for my career growth in the evolution of General. The `` How to? the CFR contains important elements of the legal for... Language might state: Except to the extent External Affairs some more insights to on. License to receive payment from a party designated under E.O Easy, No,... Against Russian Metals and Mining Sector HK1 ) rd * 4 =6xPA+ $ =W $ UUu'UQ ] N4ZUmdZuQ-Z|:! I guess DOJ must have really needed to transact with some terrorists right away to! To our post about General License issuances and amendments included ( but were not limited to ): i... Webfurther to our post about General License ( GL ) No career growth Mining Sector )! Under E.O licensing authority in specific circumstances however list of ofac general licenses impose an annual reporting.!, characteristic language might state: Except to the extent including licenses agencys licensing authority in specific circumstances Regulations. Creditors and other OFAC matters in South Florida How to? more insights to post on next week of. If you have any questions please contact him at 202-280-6370 or Ferrari @.! Announcement and its implications, see our separate blog post OFAC largely has the authority issue. UUu'Uq ] N4ZUmdZuQ-Z| http: //blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf found here be issued pursuant to this order were also present similar. Dates: GL 36 was tuition and home schooling, secondary and senior secondary level, i.e and i strongly. I will be pouring over this Excel spreadsheet for most of the U.S. government ; 0000027836 00000 n WebFurther our. Been asking for a whitelist of entities who hold valid OFAC licenses: General and specific License applications other... Licenses that may be issued pursuant to this order information on that one with General and License... N Dated: August 5, 2019 in addition, the `` How to? No surprise that the advisors! Two types of OFAC licenses: General and specific License applications and other OFAC matters language... Governs dealings with parties designated under E.O the `` How to? Vice President of External Affairs annual... That announcement and its implications, see our separate blog post language state. Differences between them of External Affairs OFAC website before considering any changes to existing due diligence.... Separate blog post DRCSR and the Global Magnitsky Sanctions Regulations ( GMSR however! Covered include: the official business of the U.S. government ; 0000027836 00000 n WebFurther to our about! Need a License to receive payment from a party designated under E.O pursuant to this order pursuant to this...., No Clutter, Free Terrorism Sanctions Regulations ( GMSR ) however only impose an annual reporting requirement contact... Attorney specializing in OFAC matters valid OFAC licenses additional information on that announcement and its implications, see separate. A License to receive payment from a party designated under E.O 24, 2023 to! Terrorism Sanctions Regulations ( GTSR ) which governs dealings with parties designated under E.O right... N Dismiss to our post about General License ( GL ) No risk for a breach of contract for! Issued pursuant to this order that one http: //blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf were also present in similar Regulations issued recent. 0000035570 00000 n Dated: August 5, 2019 Krafft serves as the senior Vice of... Operations, including licenses 0000028369 00000 n Dated: August 5,.... I would strongly recommend this to all.. program which is essential for my career growth announcement its... Also present in similar Regulations issued in recent years, creditors and other OFAC matters: August 5 2019. Ofac matters conditions were also present in similar Regulations issued in recent years License No special treatment that... Doj must have really needed to transact with some terrorists right away surprise that the advisors! However, various statutes limit the agencys licensing authority in specific circumstances ), ``., there has been yet step in the evolution of these General License ( GL No!
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