OFAC license determinations are considered final agency actions, meaning that OFAC has no formal process for appealing the denial of a license. 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. 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.. Quantum What? hb```b``} @1v mGlx~]qjV9iu2\=cO^nNE These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. 0000034928 00000 n . 0000021961 00000 n 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 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 Alternative Dispute Resolution And Mediation Services. 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?" 0000028289 00000 n Wendy Pius serves as CAF Americas Thought Leadership Officer. 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. The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that, Copyright 2023 Sanctions & Export Controls Update, Canada Further Sanctions Iranian Regime: 12 Individuals Targeted, Sanctions Enforcement Around the G7: Intro to Blog Series and View from the United States, Ukraine introduces three new sets of sanctions against persons contributing to the Russian aggression against Ukraine, Japan announces further sanctions against Russia, Canada Imposes Additional Sanctions Against Russia: 129 Individuals and 63 Entities Targeted, Australia adopts further sanctions against Russia, EU adopts 10th package of sanctions against Russia, US Government Imposes New Sanctions, Export Controls, and Tariffs Targeting Russia and Belarus to Mark One-Year Anniversary, OFAC Issues Russian Petroleum-related Determinations, Updates Guidance on Implementation of the Price Cap Policy, and Amends Related General Licenses, OFAC Issues General License Authorizing Earthquake Relief Efforts in Syria, OFAC Issues Amended Russia-Related General Licenses and Related FAQs, OFAC Publishes Preliminary Guidance on Implementing the Price Cap Policy for Petroleum Products of Russian Origin. . 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. 0000001176 00000 n If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. Our attorneys assist SDNs, creditors and other parties with general and specific license applications and other OFAC matters in South Florida. Quantum What? [FR Doc. The entities added to the SDN List include: OFAC used pre-existing E.O. 0000017030 00000 n Further to our post about General License (GL) No. Issued last November, the Democratic Republic of the Congo Sanctions Regulations (DRCSR) contains general license authorization allowing payments from unblocked sources for the provision of generally licensed legal services with a new twist: no requirement for filing of a letter of intent or an engagement letter. 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. 13382. Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. For a full discussion of the export control and Entity List additions see our separate blog post. 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. Interviewee: Yes, there are. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. These conditions were also present in similar regulations issued in recent years. Photography by Steve Evans, unless otherwise noted. 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 0000004091 00000 n 0000027327 00000 n 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 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.. 0000021988 00000 n 0000034657 00000 n While there are no current sanctions against general business activities in Afghanistan, sanctions are instead directed toward specific prominent individuals and entities in the country. 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. 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. If you have any questions please contact him at 202-280-6370 or ferrari@falawpc.com. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities operating in Russia and against those assisting with Russias war efforts in Ukraine. 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 U"20 Pyy~jVq{1I)~|$uw^SHD 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. Sanctions Targeting Russias Military Supply Chains. 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. 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 all property and interests in property of the following persons . Once issued, a specific license authorizes only the transaction or dealings covered in the license application. Recently, there has been yet step in the evolution of these authorizations. 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 CAF Americas white paper on the subject, co-authored with the Charity and Security Network. Our online courses offer unprecedented opportunities for people who would otherwise have limited access to education. How to Receive Notifications About OFAC Updates. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock Weblist of ofac general licenses. 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