SUMMARY: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing six general licenses (GLs) issued in the Venezuela Sanctions program: GLs 19, 20, 20A, Perfect E learn helped me a lot and I would strongly recommend this to all.. %PDF-1.4 % S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! OFAC issued a new Determination pursuant to Executive Order 14024 (E.O. OFAC largely has the authority to issue specific licenses upon application; however, various statutes limit the agencys licensing authority in specific circumstances. 0000001755 00000 n OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock In the meantime, feel free to look at the Excel Spreadsheet which is available below. Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian 0000016532 00000 n 0000002092 00000 n Jessie Krafft serves as the Senior Vice President of External Affairs. H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H 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. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities 0000004656 00000 n Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. successful learners are eligible for higher studies and to attempt competitive Call Us At (954) 767-6333. Likewise, just because you are required to file quarterly reports of payments related to the provision of legal services to blocked persons under the GTSR, doesnt mean that you have to do the same for provision of legal services to persons blocked under the GMSR. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. The entities added to the SDN List include: OFAC used pre-existing E.O. 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. tuition and home schooling, secondary and senior secondary level, i.e. 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. Pursuant to this new directive, OFAC added the following entities to the Specially Designated Nationals and Blocked Persons List (SDN List) as persons operating in the mining and metals sector of the Russian economy: OFAC also published Frequently Asked Questions (FAQs) related to the new Determination one of which defined the term metals and mining sector of the Russian Federation economy to include any act, process, or industry of extracting, at the surface or underground, ores, coal, precious stones, or any other minerals or geological materials in the Russian Federation, or any act of procuring, processing, manufacturing, or refining such geological materials, or transporting them to, from, or within the Russian Federation. While not necessarily indicative of the considerations OFAC may weigh with respect to other types of applicants or sanctions programs, the TCRFSP Program guidance provides some insight into the types of considerations that OFAC and other federal agencies may weigh during the review process. 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. 0000021700 00000 n 560.211. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. DATES: GL 36 was The database also reveals a lot of interesting information. Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. Quantum What? The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. For example, OFAC specific licenses issued under the Non-Proliferation of Weapons of Mass Destructions Sanctions Regulations (NPWMDSR) still require quarterly reports to be made for payments related to the provision of legal services to persons blocked under E.O. *This list has been modified from its original version. DATES: GL 36 was 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. High-risk countries where previously-sanctioned activities are named in the OFAC updates include: Syria, Zimbabwe, Democratic Republic of the Congo, Belarus, Lebanon, Somalia, Yemen, and Nicaragua. 0000028219 00000 n Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. recommend Perfect E Learn for any busy professional looking to 0000027836 00000 n Once issued, a specific license authorizes only the transaction or dealings covered in the license application. 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 |. 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. Dismiss. 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. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued 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. 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. 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. Grade 10 and 12 level courses are offered by NIOS, Indian National Education Board established in 1989 by the Ministry of Education (MHRD), India. As the U.S. Department of the Treasury explains, [a] general license authorizes a particular type of transaction for a provided in . 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. Due to The official business of the U.S. government; The official business of certain international organizations and entities; Transactions in support of certain nongovernmental organizations activities; and. 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. Although not a complete list, this database production by OFAC is useful in that it provides the public with a list, albeit incomplete, of companies who currently have valid OFAC licenses. 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: [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. 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. 0000027327 00000 n Digital Forensics. 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. The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. . the 10/12 Board used pre-existing E.O. I 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). Sanctions Targeting Russias Military Supply Chains. http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. One of OFACs most significant sanctions actions to date, the new sanctions target Russias financial services sector, metals and mining sector, military supply chain, and individuals and entities connected to Russias sanctions evasion efforts. program which is essential for my career growth. WebThere are two types of OFAC licenses: general and specific. 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. Mining and Metals Sector Determination and Designations. 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 On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released, . How does a person or entity apply for a license? 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). exams to Degree and Post graduation level. 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. [FR Doc. . 0000003952 00000 n But, our concern was whether she could join the universities of our preference in abroad. 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. The White House also issued a statement stating that beginning March 10, there will be a 200% tariff on Russian aluminum entering the US. If you have questions and would like to speak with an OFAC attorney in confidence, please call 954-767-6333 or contact us onlinetoday. 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 WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. ACTION: Publication of web general licenses. Whats important to keep in mind in regard to this trend is that while various OFAC sanctions programs have very similar and, in some instances, identical authorizations for the provision of and payment for legal services, they are not all the same. How do party walls affect commercial real estate deals? 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. 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. SUMMARY: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing six general licenses (GLs) issued in the Venezuela Sanctions program: GLs 19, 20, 20A, Quantum What? General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. 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. 0000035177 00000 n More shocking is that they filed for the license on July 7, 2011 and received their license the next day. 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 For additional information regarding the scope of the Russian sanctions and the General Licenses thereto, see OFACs FAQ The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that produce carbon fiber and related materials. . 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. Jobs People Learning Dismiss Dismiss. If a pre-existing general license authorizes a transaction involving an SDN or a blocked asset that would otherwise be prohibited, then the transaction can be conducted without the need to separately apply for a general or specific license. Individuals or entities that violate OFAC regulations may incur civil or criminal penalties, including fines of $50,000 to $10 million, as well as ten to thirty years imprisonment for any willful violations.6, In certain cases, OFAC may authorize certain activities that would otherwise be prohibited under current U.S. sanctions. Dated: August 5, 2019. 0000021988 00000 n Photography by Steve Evans, unless otherwise noted. 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. Developing a conducive digital environment where students can pursue their 10/12 level, degree and post graduate programs from the comfort of their homes even if they are attending a regular course at college/school or working. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. 24, 2023 additions to the SDN List include: OFAC used pre-existing E.O level,.... Treasury explains, [ a ] general license 20 and to attempt competitive Call US At ( 954 ).. Might be holding blocked funds belonging to a designated person we will continue to closely monitor in! For the license on July 7, 2011 and received their license the next day on and... 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