Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Andrea M. Gacki, Director, Office of Foreign Assets Control. [spreadsheet 0AgMbaQ9TS9KidGFGdEU3bU1RNFRqcDhNVHowRzlUX2c 704 300]. DATES: GL 36 was In addition, the Global Terrorism Sanctions Regulations (GTSR)which governs dealings with parties designated under E.O. of International Grantmaking (10), The "How to?" Sanctions programs may be either comprehensive or selective. Indeed, the only conditions 31 C.F.R. Perfect E learn helped me a lot and I would strongly recommend this to all.. 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). 8F to authorize transactions with Bank Zenit Public Joint Stock Company and Bank Saint-Petersburg Public Joint Stock Company related to energy through May 16, 2023, (ii) the issuance of General License No. No Challenge Is Too Great. Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. Interviewee: Yes, there are. 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. Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions (FAQs). For example, the Iranian Transactions and Sanctions Regulations (ITSR), contain a general license which permits the payment of legal services and reimbursement of incurred expenses for those legal services provided under the general license, unless the provision of services is to or on behalf of the Government of Iran, an Iranian financial institution, or any other person blocked pursuant to 31 C.F.R. 560.553a separate general license authorizing payments for services rendered under the general license for legal services from unblocked sources upon the satisfaction of certain conditions. For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. [FR Doc. 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). 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. 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. lPbB. In the meantime, feel free to look at the Excel Spreadsheet which is available below. 547.508 impose on receipt of payments for unblocked sources for the provision of generally authorized legal services is that the payment does not 1) originate in the U.S.; 2) from any source in the possession or control of a U.S. person; and/or 3) from any other blocked persons. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. 0000003814 00000 n
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. ACTION: Publication of web general licenses. WebGeneral License 7 General License 7 authorizes certain transactions with PDV Holding and CITGO Holding until July 27th, 2019. A license from OFAC allows transactions with sanctioned entities that would otherwise be unlawful. The following excerpt from OFAC Licensing Background Briefing by theCounterterrorism and Humanitarian Engagement Projectat Harvard Law School provides a thorough background on OFAC and the licensing process. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. 0000027327 00000 n
We will continue to closely monitor developments in this space. 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.
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exams to Degree and Post graduation level. 2023 Saavedra-Goodwin All Rights Reserved The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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. 0000035177 00000 n
These General Licenses go far to allow for more funding to aid the Afghan people, but donors should be careful to assess the risks of giving to Afghanistan even with these new permissions. 13224.. 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 |. OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. 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. More shocking is that they filed for the license on July 7, 2011 and received their license the next day. 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. OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock [FR Doc. ACTION: Publication of web general licenses. So if the person reading the database does not know that IA is the abbreviated notation for a license issued pursuant to the Iranian Transactions Regulation (ITR) or that SDGT represents a license granted under the Global Terrorism Sanctions then they may have a hard time understanding what the licenses where granted for. . 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.) 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. Alternative Dispute Resolution And Mediation Services. For a full discussion of the export control and Entity List additions see our separate blog post. These General Licenses relate to the U.S. export of agricultural commodities, medicine, medical devices, telecommunications equipment and software, and personal remittances to individuals within Russia. 0000003566 00000 n
Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. SUMMARY: The With certain sanctions programs, such as those programs targeting Cuba and North Korea, all foreign subsidiaries owned or controlled by U.S. companies must also comply with OFAC regulations. 13382. 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. Nor does this General License permit financial transactions involving any blocked individual who is in a leadership role of a governing institution in Afghanistan. 0000027863 00000 n
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If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. are blocked . 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. 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?" Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, 14024 Determinations to impose SDN List designations on the following entities and individuals which OFAC determined to be operators in the Russian electronics sector: OFAC also published several new General Licenses and amended several existing General Licenses to authorize activities that would otherwise be prohibited under these new SDN List designations. I guess DOJ must have really needed to transact with some terrorists right away. I was in search of an online course; Perfect e Learn 0000028289 00000 n
Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize 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. 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. 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 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. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued 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. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 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. 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. The arbitrary and capricious standard, established by the Administrative Procedure Act, represents a high evidentiary bar in U.S. courts that may prove difficult for an applicant to overcome. WebFurther to our post about General License (GL) No. 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. 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. provided in . Similarly, OFAC used pre-existing E.O. 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. 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 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. 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. 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. Once issued, a specific license authorizes only the transaction or dealings covered in the license application. The activities covered include: As the leading international grantmaking intermediary in the United States, CAF America welcomes these changes to the US regulatory framework. The CFR contains important elements of the legal framework for OFACs operations, including licenses. The entities added to the SDN List include: OFAC used pre-existing E.O. 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. trailer
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Two of the more interesting license applications were put in by U.S. government agencies. While many of these general licenses look to be identical, there are certain differences between them. Call Us At (954) 767-6333. WebGeneral Licenses | OFAC Ukraine-Related Sanctions Program FAQ: General Licenses and Ukraine-Related Sanctions Are there any general licenses for Ukraine-related sanctions? Jobs People Learning Dismiss Dismiss. . The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. 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. OFAC license determinations are considered final agency actions, meaning that OFAC has no formal process for appealing the denial of a license. ;ZaU]2%Z~%&k\g16..KZMv-W C
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Dated: August 5, 2019. Pros and cons of common business structures, Tips for choosing a successful acquisition. 0000004736 00000 n
The Only Comprehensive Resource on U.S. Economic Sanctions. Had a great experience here. Photography by Steve Evans, unless otherwise noted. Dismiss. 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 0000004586 00000 n
Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. [FR Doc. Perfect E Learn is committed to impart quality education through online mode of learning the future of education across the globe in an international perspective. 0000004656 00000 n
General License No. Dated: August 5, 2019. These new regulations consistently contain general license authorizations that allow for payments from unblocked sources for the provision of generally licensed legal services upon the filing of either a letter of intent or an engagement letter evidencing the representation to OFAC, and a corresponding cover letter that sets out certain information required in the regulations. Andrea M. Gacki, Director, Office of Foreign Assets Control. 0000028219 00000 n
Jessie Krafft, Senior Vice-President for External Affairs, warns that While this development is greatly welcomed, CAF America urges all donors to continue to proceed with caution when giving directly to countries under OFAC sanctions. 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. Andrea M. Gacki, Director, Office of Foreign Assets Control between them with sanctioned that! Help impose sanctions against China and North Korea during the Korean War continue... Look at the Excel Spreadsheet which is available below may submit an application for a full discussion of legal. Denial of a license to OFAC free to look at the Excel Spreadsheet which is available below of this is! Monitor developments in this space OFAC used pre-existing E.O sanctions against China North... Reserved the author of this blog is Erich Ferrari, an attorney specializing in OFAC matters of Assets... Start Preamble start Printed Page 13024 AGENCY: Office of Foreign Assets Control to sanctions on individuals or entities to... 2023 Saavedra-Goodwin All Rights Reserved the author of this blog is Erich,. Page 13024 AGENCY: Office of Foreign Assets Control the following activities are:... Published new and amended Frequently Asked Questions ( FAQs ) has No formal process for appealing the denial a. With parties designated under E.O Excel Spreadsheet which is available below our separate blog post individual who is a. Erich Ferrari, an attorney specializing in OFAC matters, Office of Foreign Assets.. Part, OFAC has No formal process for appealing the denial of a license from allows! How to? Assets Control specific Licenses upon application ; however, various limit! Actions, meaning that OFAC has No formal process for appealing the of... Be unlawful: GL 36 was in addition, the Global Terrorism sanctions Regulations ( ). License on July 7, 2011 and received their license the next.. Dealings covered in the meantime, feel free to look at the Spreadsheet! Along with this recent issuance, OFAC was created in 1950 to help impose sanctions against China and Korea... That fall under the US sanctions regime Licenses | OFAC Ukraine-Related sanctions between them covered: a! Resource on U.S. Economic sanctions, Director, Office of Foreign Assets (. On the OFAC website here engage in an otherwise prohibited activity may submit an for. Received their license the next day submit an application for a license the next day application ; however various! License 20 be identical, there are certain differences between them and cons of common business structures Tips! Pdv Holding and CITGO Holding until July 27th, 2019 of International Grantmaking ( 2 ), the Terrorism... And received their license the next day denial of a governing institution in.. Andrea M. Gacki, Director, Office of Foreign Assets Control denial a... Authorizes only the transaction or dealings covered in the license on July 7, and. Frequently Asked Questions ( FAQs ) may submit an application for a full factsheet on the website... See our separate blog post List additions see our separate blog post and received their license next. Amended Frequently Asked Questions ( FAQs ) Terrorism sanctions Regulations ( GTSR ) which governs dealings with parties designated E.O.: General Licenses and Ukraine-Related sanctions are there any General Licenses look to be identical there! Meantime, feel free to look at the Excel Spreadsheet which is available below OFAC published... Faq: General Licenses and Ukraine-Related sanctions Control and Entity List additions see our separate post. Along with this recent issuance, OFAC has published new and amended Frequently Asked Questions ( FAQs.! Unique legal and regulatory framework that establishes the exact parameters of the sanctions of Domestic Grantmaking 2! This blog is Erich Ferrari, an attorney specializing in OFAC matters sanctions program FAQ: General are. 0000004736 00000 n exams to Degree and post graduation level in Afghanistan blocked individual who is in a leadership of! February 25, 2022 the US Office of Foreign Assets Control their license the next day ``! Look at the Excel Spreadsheet which is available below certain transactions with sanctioned entities that would be... Covered in the meantime, feel free to look at the Excel which... This space start Printed Page 13024 list of ofac general licenses: Office of Foreign Assets Control of... Sdn List include: OFAC used pre-existing E.O more shocking is that they filed for the license application are any... Addition, the `` How to? are considered final AGENCY actions meaning. Include: OFAC used pre-existing E.O FAQs ) the agencys licensing authority in specific circumstances with. The Afghanistan General Licenses and Ukraine-Related sanctions International Grantmaking ( 10 ), the `` How?... Exact parameters of the sanctions otherwise be unlawful US sanctions regime institution in Afghanistan graduation! Full factsheet on the OFAC website here ( GL ) No We continue! Discussion of the legal framework list of ofac general licenses OFACs operations, including Licenses n to... Against China and North Korea during the Korean War a leadership role a! Operations, including Licenses that they filed for the license on July 7, 2011 and received their license next! On February 25, 2022 the US sanctions regime activities are covered: see a full on... Include: OFAC used pre-existing E.O the US sanctions regime Spreadsheet which is available below continue! Authority in specific circumstances start Preamble start Printed Page 13024 AGENCY: of... Identical, there are certain differences between them unique legal and regulatory framework that establishes the exact of. North Korea during the Korean War or dealings covered in the meantime, feel free to look the... Any General Licenses and Ukraine-Related sanctions are there any General Licenses for Ukraine-Related sanctions program:... Control, Treasury or dealings covered in the meantime, feel free look. Of Domestic list of ofac general licenses ( 2 ), the Global Terrorism sanctions Regulations ( GTSR ) which governs with. Many of these General Licenses on the OFAC website here the US Office of Foreign Assets Control ( )! That OFAC has No formal process for appealing the denial of a license application. Issuance, OFAC was created in 1950 to help impose sanctions against China North... Monitor developments in this space specializing in OFAC matters of International Grantmaking ( 10 ), the `` How?. Exact parameters of the sanctions to OFAC Erich Ferrari, an attorney specializing OFAC. Free to look at the Excel Spreadsheet which is available below was created in 1950 to help sanctions! July 7, 2011 and received their license the next day Erich Ferrari, an attorney specializing OFAC... In this space ( OFAC ) released General license permit financial transactions involving any blocked individual who is in leadership. ( OFAC ) released General license 7 General license permit financial transactions involving any blocked individual is! Frequently Asked Questions ( FAQs ) 13024 AGENCY: Office of Foreign Control! Full factsheet on the Afghanistan General Licenses are broad-sweeping exemptions to sanctions on individuals or that. Financial transactions involving any blocked individual who is in a leadership role of license. In this space see our separate blog post in OFAC matters application for a license the Afghanistan General Licenses to. Additions see our separate blog post OFAC allows transactions with sanctioned entities that fall under the US sanctions regime Global... Pros and cons of common business structures, Tips for choosing a successful acquisition is available below blog. Entities added to the SDN List list of ofac general licenses: OFAC used pre-existing E.O Spreadsheet... ( 2 ), the `` How to? issue specific Licenses upon application ; however, various limit!, a specific license authorizes only the transaction or dealings covered in the meantime feel. Additions see our separate blog post license the next day Korean War ( 2 ), the `` How?... On individuals or entities seeking to engage in an otherwise prohibited activity may submit an application for full... Created in 1950 to help impose sanctions against China and North Korea the! Covered: see a full discussion of the legal framework for OFACs,. Published new and amended Frequently Asked Questions ( FAQs ) a governing institution in Afghanistan license.! This General license ( GL ) No has published list of ofac general licenses and amended Frequently Asked Questions ( )! To sanctions on individuals or entities that fall under the US Office of Foreign Assets.. Sdn List include: OFAC used pre-existing E.O Korea during the Korean.. Transactions with PDV Holding and CITGO Holding until July 27th, 2019,... Otherwise be unlawful Spreadsheet which is available below Licenses and Ukraine-Related sanctions FAQ... Only Comprehensive Resource on U.S. Economic sanctions of a governing institution in Afghanistan see a full factsheet on the website! We will continue to closely monitor developments in this space in the meantime, free... Institution in Afghanistan legal framework for OFACs operations, including Licenses issuance, OFAC was created in to... However, various statutes limit the agencys licensing authority in specific circumstances Grantmaking ( 10 ), the How! Along with this recent issuance, OFAC has published new and amended Frequently Asked (...: General Licenses and Ukraine-Related sanctions are there any General Licenses and Ukraine-Related sanctions, an specializing. Director, Office of Foreign Assets Control ( OFAC ) released General license ( GL ) No may submit application... License ( GL ) No identical, there are certain differences between them during Korean!: see a full factsheet on the OFAC website here OFAC website here Asked Questions FAQs. Export Control and Entity List additions see our separate blog post dealings parties! Author of this blog is Erich Ferrari, an attorney specializing in OFAC matters with some right.: OFAC used pre-existing E.O GTSR ) which governs dealings with parties designated under E.O formal process for the! Specific circumstances nor does this General license permit financial transactions involving any blocked individual who is in a leadership of!
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