dx%o%fjn,Vvoy{"i )u (@!%d%@B x@ hHk XD O8xo0]`{mPp}`lC]x'08k07x|AAkFA,"|=>f{nvO~! This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. Hj 0 endstream endobj 595 0 obj <>stream BIS adds a sentence to the end of new paragraph (a)(1)(iii) under 746.7 to specify that reexports and exports from abroad of foreign-produced items that would have otherwise met all of the terms and conditions of an OFAC general license if the transactions had been subject to OFAC license requirements are exempt from BIS license Interviewee: Yes, there are. The activities covered include: The official business of the U.S. government; Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. 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. 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 Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" have discontinued my MBA as I got a sudden job opportunity after 0000021988 00000 n 0000016950 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. of International Grantmaking. DATES: GL 36 was While many of these general licenses look to be identical, there are certain differences between them. 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. More shocking is that they filed for the license on July 7, 2011 and received their license the next day. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. Dismiss. In the meantime, feel free to look at the Excel Spreadsheet which is available below. **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. The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. OFAC also published several new General Licenses and amended several existing General Licenses to authorize activities that would otherwise be prohibited 0000004586 00000 n On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . WebFurther to our post about General License (GL) No. 0000003413 00000 n Director, Office of Foreign Assets Control. 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. For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC 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 Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials, replaces and supersedes GL 6B (see previous blog post here), On December 30, 2022, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) issued Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (Petroleum Products Guidance). 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: [HOT] Read Latest COVID-19 Guidance, All Aspects [SCHEDULE] Upcoming COVID-19 Webinars & Online Programs, [GUIDANCE] COVID-19 and Force Majeure Considerations, [GUIDANCE] COVID-19 and Employer Liability Issues. 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. 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. Further to our post about General License (GL) No. She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding. Grade 10 and 12 level courses are offered by NIOS, Indian National Education Board established in 1989 by the Ministry of Education (MHRD), India. 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). Director, Office of Foreign Assets Control. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! 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. 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. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program OFAC Licenses: Do You Need a General License or a Specific License? If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. 2023 Saavedra-Goodwin All Rights Reserved 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. The White House also issued a statement stating that beginning March 10, there will be a 200% tariff on Russian aluminum entering the US. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p Once issued, a specific license authorizes only the transaction or dealings covered in the license application. used pre-existing E.O. The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. 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. . DATES: GL 36 was How to Receive Notifications About OFAC Updates. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. The most important ones pertain to banks that might be holding blocked funds belonging 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 Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. 0000021700 00000 n Quantum What? W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx Photography by Steve Evans, unless otherwise noted. 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. [FR Doc. Jobs People Learning Dismiss Dismiss. 0000004656 00000 n We will continue to closely monitor developments in this space. Dismiss. These new General Licenses (GL 14, 15, 16, 17, 18, & 19) allow for specific business dealings with entities that are tied to the Taliban and the Haqqani Network, both of which are Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 and many of whose members are also found on on the SDN list. tuition and home schooling, secondary and senior secondary level, i.e. 0000021398 00000 n OFAC license determinations are considered final agency actions, meaning that OFAC has no formal process for appealing the denial of a license. xJx 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, turning any previous work in Afghanistan into a regulatory minefield. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued . Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. 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 Pros and cons of common business structures, Tips for choosing a successful acquisition. I Alternative Dispute Resolution And Mediation Services. 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. 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. OF THE TREASURY (Feb. 24, 2023), https://home.treasury.gov/news/press-releases/jy1298. Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. Andrea M. Gacki, Director, Office of Foreign Assets Control. 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. ACTION: Publication of web general licenses. 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. Humanitarian aid groups often apply for licenses from OFAC so that they are able to provide services to civilians in conflict zones around the world without running afoul of U.S. sanctions law. We follow a systematic approach to the process of learning, examining and certifying. 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. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Director, Office of Foreign Assets Control. Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. Sanctions programs may be either comprehensive or selective. 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.) '&eeLuM21usXIeUvbt{K"]T@{PMaL}NHz(2P#C%qs[ e5K,wf!o5HO~S,Ldb;E IKA/?Ndh__h#<3ZP~ +,(($ .0 m endstream endobj 586 0 obj <> endobj 587 0 obj <> endobj 588 0 obj <> endobj 589 0 obj <> endobj 590 0 obj <> endobj 591 0 obj [597 0 R] endobj 592 0 obj <>stream Dismiss. 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. 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. Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. 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. 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). 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. 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). 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. But, our concern was whether she could join the universities of our preference in abroad. 0000002748 00000 n 0000027327 00000 n This Determination is similar to existing Determinations and other Executive Orders which have authorized OFAC to impose blocking sanctions on persons operating in different sectors of Russias economy including: quantum computing, accounting, trust and corporate formation, management consulting, aerospace, marine, electronics, financial services, technology, and defense and related material sectors of Russia. 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. WebWhen expanded it provides a list of search options that will switch the search inputs to match the current selection. 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. 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! 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. If you have any questions please contact him at 202-280-6370 or ferrari@falawpc.com. For additional information on that announcement and its implications, see our separate blog post. 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. 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.. 0000027863 00000 n 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 Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions (FAQs). 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. 0000034928 00000 n OFAC noted that these broad, sweeping sanctions will further isolate Russia from the international economy and hinder Russias ability to obtain the capital, materials, technology, and support that sustain its war against Ukraine. SUMMARY: The 14024) which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy. He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). 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. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. . 0000035177 00000 n 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. Indeed, the only conditions 31 C.F.R. Weblist of ofac general licenses. These conditions were also present in similar regulations issued in recent years. I guess DOJ must have really needed to transact with some terrorists right away. 0000016263 00000 n 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 Educational programs for all ages are offered through e learning, beginning from the online 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. Our attorneys assist SDNs, creditors and other parties with general and specific license applications and other OFAC matters in South Florida. Determination Against Russian Metals and Mining Sector First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a These sanctions programs are designed to enable the United States to accomplish its national security and foreign policy goals.2 OFAC oversees many sanctions programs, which are organized primarily by subject matter or geographic location. General License 23 does not authorize importation of petroleum or petroleum products of, On January 17, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) amended (i) certain Russia-related General Licenses (GLs) and (ii) four Russia-related Frequently Asked Questions (FAQs). 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. of International Grantmaking, The How to? of Domestic Grantmaking. The Only Comprehensive Resource on U.S. Economic Sanctions. The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. The database also reveals a lot of interesting information. 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. Shooting In Edinburg Tx Last Night, Usa Swimming Time Standards Short Course, Clonbinane Homestead, Delaware County Oklahoma Accident Reports, Articles L
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list of ofac general licenses

Thank you #OFAC for today's #Syria earthquake relief license. 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.. Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. Although it does not appear that OFAC has published the Guidance as part of 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 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 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~! This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. Hj 0 endstream endobj 595 0 obj <>stream BIS adds a sentence to the end of new paragraph (a)(1)(iii) under 746.7 to specify that reexports and exports from abroad of foreign-produced items that would have otherwise met all of the terms and conditions of an OFAC general license if the transactions had been subject to OFAC license requirements are exempt from BIS license Interviewee: Yes, there are. The activities covered include: The official business of the U.S. government; Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. 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. 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 Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" have discontinued my MBA as I got a sudden job opportunity after 0000021988 00000 n 0000016950 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. of International Grantmaking. DATES: GL 36 was While many of these general licenses look to be identical, there are certain differences between them. 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. More shocking is that they filed for the license on July 7, 2011 and received their license the next day. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. Dismiss. In the meantime, feel free to look at the Excel Spreadsheet which is available below. **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. The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. OFAC also published several new General Licenses and amended several existing General Licenses to authorize activities that would otherwise be prohibited 0000004586 00000 n On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . WebFurther to our post about General License (GL) No. 0000003413 00000 n Director, Office of Foreign Assets Control. 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. For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC 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 Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials, replaces and supersedes GL 6B (see previous blog post here), On December 30, 2022, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) issued Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (Petroleum Products Guidance). 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: [HOT] Read Latest COVID-19 Guidance, All Aspects [SCHEDULE] Upcoming COVID-19 Webinars & Online Programs, [GUIDANCE] COVID-19 and Force Majeure Considerations, [GUIDANCE] COVID-19 and Employer Liability Issues. 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. 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. Further to our post about General License (GL) No. She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding. Grade 10 and 12 level courses are offered by NIOS, Indian National Education Board established in 1989 by the Ministry of Education (MHRD), India. 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). Director, Office of Foreign Assets Control. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! 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. 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. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program OFAC Licenses: Do You Need a General License or a Specific License? If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. 2023 Saavedra-Goodwin All Rights Reserved 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. The White House also issued a statement stating that beginning March 10, there will be a 200% tariff on Russian aluminum entering the US. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p Once issued, a specific license authorizes only the transaction or dealings covered in the license application. used pre-existing E.O. The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. 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. . DATES: GL 36 was How to Receive Notifications About OFAC Updates. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. The most important ones pertain to banks that might be holding blocked funds belonging 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 Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. 0000021700 00000 n Quantum What? W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx Photography by Steve Evans, unless otherwise noted. 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. [FR Doc. Jobs People Learning Dismiss Dismiss. 0000004656 00000 n We will continue to closely monitor developments in this space. Dismiss. These new General Licenses (GL 14, 15, 16, 17, 18, & 19) allow for specific business dealings with entities that are tied to the Taliban and the Haqqani Network, both of which are Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 and many of whose members are also found on on the SDN list. tuition and home schooling, secondary and senior secondary level, i.e. 0000021398 00000 n OFAC license determinations are considered final agency actions, meaning that OFAC has no formal process for appealing the denial of a license. xJx 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, turning any previous work in Afghanistan into a regulatory minefield. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued . Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. 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 Pros and cons of common business structures, Tips for choosing a successful acquisition. I Alternative Dispute Resolution And Mediation Services. 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. 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. OF THE TREASURY (Feb. 24, 2023), https://home.treasury.gov/news/press-releases/jy1298. Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. Andrea M. Gacki, Director, Office of Foreign Assets Control. 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. ACTION: Publication of web general licenses. 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. Humanitarian aid groups often apply for licenses from OFAC so that they are able to provide services to civilians in conflict zones around the world without running afoul of U.S. sanctions law. We follow a systematic approach to the process of learning, examining and certifying. 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. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Director, Office of Foreign Assets Control. Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. Sanctions programs may be either comprehensive or selective. 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.) '&eeLuM21usXIeUvbt{K"]T@{PMaL}NHz(2P#C%qs[ e5K,wf!o5HO~S,Ldb;E IKA/?Ndh__h#<3ZP~ +,(($ .0 m endstream endobj 586 0 obj <> endobj 587 0 obj <> endobj 588 0 obj <> endobj 589 0 obj <> endobj 590 0 obj <> endobj 591 0 obj [597 0 R] endobj 592 0 obj <>stream Dismiss. 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. 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. Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. 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. 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). 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. 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). 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. But, our concern was whether she could join the universities of our preference in abroad. 0000002748 00000 n 0000027327 00000 n This Determination is similar to existing Determinations and other Executive Orders which have authorized OFAC to impose blocking sanctions on persons operating in different sectors of Russias economy including: quantum computing, accounting, trust and corporate formation, management consulting, aerospace, marine, electronics, financial services, technology, and defense and related material sectors of Russia. 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. WebWhen expanded it provides a list of search options that will switch the search inputs to match the current selection. 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. 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! 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. If you have any questions please contact him at 202-280-6370 or ferrari@falawpc.com. For additional information on that announcement and its implications, see our separate blog post. 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. 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.. 0000027863 00000 n 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 Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions (FAQs). 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. 0000034928 00000 n OFAC noted that these broad, sweeping sanctions will further isolate Russia from the international economy and hinder Russias ability to obtain the capital, materials, technology, and support that sustain its war against Ukraine. SUMMARY: The 14024) which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy. He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). 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. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. . 0000035177 00000 n 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. Indeed, the only conditions 31 C.F.R. Weblist of ofac general licenses. These conditions were also present in similar regulations issued in recent years. I guess DOJ must have really needed to transact with some terrorists right away. 0000016263 00000 n 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 Educational programs for all ages are offered through e learning, beginning from the online 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. Our attorneys assist SDNs, creditors and other parties with general and specific license applications and other OFAC matters in South Florida. Determination Against Russian Metals and Mining Sector First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy who advise OFAC on license applicationsapplied for a These sanctions programs are designed to enable the United States to accomplish its national security and foreign policy goals.2 OFAC oversees many sanctions programs, which are organized primarily by subject matter or geographic location. General License 23 does not authorize importation of petroleum or petroleum products of, On January 17, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) amended (i) certain Russia-related General Licenses (GLs) and (ii) four Russia-related Frequently Asked Questions (FAQs). 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. of International Grantmaking, The How to? of Domestic Grantmaking. The Only Comprehensive Resource on U.S. Economic Sanctions. The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. The database also reveals a lot of interesting information. 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.

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list of ofac general licensesa comment