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. 13224 and contains a general license authorization allowing payments for the provision of generally authorized legal services from unblocked sourcesalso maintains a quarterly reporting requirement. The full article can be foundhere. at a difficult time for the country of Afghanistan, as it faces the threat of a public health crisis, drought, and economic collapse. Dismiss. 0000004091 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. Had a great experience here. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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 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. Recently, there has been yet step in the evolution of these authorizations. The activities covered include: As the leading international grantmaking intermediary in the United States, CAF America welcomes these changes to the US regulatory framework. Quantum What? 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. 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. 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. 0000003678 00000 n 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. 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. Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p 61 to authorize certain transactions through May 25, 2023 related to the divestment or transfer of debt or equity of or the winding down of derivative contracts issued by certain financial institutions blocked on February 24, 2023. [FR Doc. OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. December 23, 2021. He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). . M_;C}EZrB"F${#4eq3mI4\/X|L@# XruR {WzGc d>dx%o%fjn,Vvoy{"i )u (@!%d%@B x@ hHk XD O8xo0]`{mPp}`lC]x'08k07x|AAkFA,"|=>f{nvO~! 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 For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. General License No. 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 United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has discretion to both specifically license particular transactions, as well as broadly generally authorizei.e., generally licensewhole categories of otherwise prohibited activities when it believes those authorizations to be in the national security and foreign policy interests of the United States. In order to transfer assets as a specially designated national (SDN) or to engage in transactions involving an SDNs blocked assets, it is necessary to obtain a license from the Office of Foreign Asset Control (OFAC). 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. Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. Dismiss. 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. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. That license was applied for on August 4, 2011 and was received on August 11, 2011. I 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. xJx 0000035204 00000 n 0000016950 00000 n That license was granted under the Global Terrorist Sanctions Regulations and also has no expiration date. Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions (FAQs). 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 most important ones pertain to banks that might be holding blocked funds belonging 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. Grade 10 and 12 level courses are offered by NIOS, Indian National Education Board established in 1989 by the Ministry of Education (MHRD), India. 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. 0000021700 00000 n OFAC also published several new General Licenses and amended several existing General Licenses to authorize activities that would otherwise be prohibited Our online courses offer unprecedented opportunities for people who would otherwise have limited access to education. of International Grantmaking. 0000003814 00000 n 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.. Photography by Steve Evans, unless otherwise noted. have discontinued my MBA as I got a sudden job opportunity after 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). 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. 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. Dated: August 5, 2019. The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that produce carbon fiber and related materials. H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H of International Grantmaking (10), The "How to?" 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. 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 author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 0000034657 00000 n 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. Specific licenses are commonly used to obtain authorization for the release of SDNs blocked assets, but they can be utilized under various other scenarios as well. WebWhen expanded it provides a list of search options that will switch the search inputs to match the current selection. Interviewee: Yes, there are. Director, Office of Foreign Assets Control. We will continue to closely monitor developments in this space. 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. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities By issuing General License J-1, OFAC has started to provide its answer, as this particular ;ZaU]2%Z~%&k\g16..KZMv-W C endstream endobj 593 0 obj <> endobj 594 0 obj <>stream 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.. My childs preference to complete Grade 12 from Perfect E Learn was almost similar to other children. ACTION: Publication of web general licenses. I strongly 0000035570 00000 n HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| 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. 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 Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. Note 1 to paragraph ( b ) (3) of 542.211: 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 0000021398 00000 n 14024 Determinations to impose SDN List designations on, CBP Releases New Resources for UFLPA Enforcement & Applicability Reviews, Biden Administration Increases Tariffs on Russian Aluminum and 100 Other Products on One Year Anniversary of Russias Invasion of Ukraine, OFAC Continues to Take Aim at Russias Financial Sector with More SDN Designations, OFAC's Crackdown on Tornado Cash Protocol Raises Specter of Future Liability Concerns, OFAC and State Department Designate Severstal, Nord Gold and Additional Russians as SDNs. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . 0000027863 00000 n 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.) Quantum What? . 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. 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. 0000004656 00000 n On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. 13382. The activities covered include: The official business of the U.S. government; 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. 0000034928 00000 n all property and interests in property of the following persons . program which is essential for my career growth. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize NIOS helped in fulfilling her aspiration, the Board has universal acceptance and she joined Middlesex University, London for BSc Cyber Security and helped me to continue my class without quitting job. 0000028289 00000 n 0000021961 00000 n Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 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 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. Hj 0 endstream endobj 595 0 obj <>stream On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities For instance, OFAC states that it may conduct background investigations of each owner, significant shareholder, director, manager, and other key employee [sic] that will be directly involved in the applicants Cuba-related business.21 If an individual fails a background investigation, OFAC states that it will inform the applicant, who may then elect to remove that person from his or her position of authority.22. The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. 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. 0000027327 00000 n Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. If you have any questions please contact him at 202-280-6370 or ferrari@falawpc.com. Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. For instance, characteristic language might state: Except to the extent . 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. 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 |. http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. 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. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program 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. Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. 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. 13224.. 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list of ofac general licenses