Our online courses offer unprecedented opportunities for people who would otherwise have limited access to education. On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities Quantum What? The sanctions also highlight the USs use of secondary sanctions to sanction individuals and entities aiding Russias war efforts, assisting with sanctions evasion, and the backfilling of necessary parts, components, and materials. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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. OFAC broadly states that its licensing determinations are guided by U.S. foreign policy and national security concerns and may involve coordination with other federal agencies, including the U.S. Department of State and the U.S. Department of Commerce.18 One reason that other agencies may be brought in to deliberate a license application involves the content of the application: for instance, if the proposed license involves exports, the Commerce Department may participate in the approval process.19 If the proposed license implicates State Department regulations, such as arms trafficking, then the State Department may also review the license application.20 In its guidance on the Traveler, Carrier, and Remittance Forwarding Service Provider Program (TCRFSP Program), OFAC provides some additional information on the factors it may consider when granting service provider licenses in the context of its Cuban sanctions program. 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. 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 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. 0000035657 00000 n 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. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. 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. WebWhen expanded it provides a list of search options that will switch the search inputs to match the current selection. 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. trailer <]/Prev 201093/XRefStm 1755>> startxref 0 %%EOF 623 0 obj <>stream [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. 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. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. Those entities include: OFAC also designated OOO Zenit Finance, OOO Zenit Leasing, and OOO Zenit Factoring MSP as SDNs for being owned or controlled by or acting on behalf of Bank Zenit. 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. 0000016880 00000 n The activities covered include: The official business of the U.S. government; Online tuition for regular school students and home schooling children with clear options for high school completion certification from recognized boards is provided with quality content and coaching. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 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. Jobs People Learning Dismiss Dismiss. all property and interests in property of the following persons . H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H Dismiss. 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. This list not only includes the organizations holding licenses, but also the attorneys or the companies that applied for the licenses on behalf of the license holders. 0000003814 00000 n used pre-existing E.O. 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. develop their business skills and accelerate their career program. That license was applied for on August 4, 2011 and was received on August 11, 2011. 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. 0000002634 00000 n As explained by OFAC, [a] general license authorizes a particular type of transaction for a class of persons without the need to apply for a license. For example, General License No. 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. Director, Office of Foreign Assets Control. Determination Against Russian Metals and Mining Sector Sanctions programs may be either comprehensive or selective. Examples of comprehensive sanctions programs include Burma (Myanmar), Cuba, Iran, Sudan, and Syria.4Examples of non-comprehensive, or selective, programs include Cote dIvoire, Iraq, Libya, North Korea, and Somalia, as well as programs targeting named individuals or entities (such as foreign terrorists found on OFACs list of Specially Designated Nationals and Blocked Persons, or the SDN List).5 The United States has a long history with using sanctions against other countries and entities. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program That guidance provides additional information on the respective license application requirements for those sanctions programs.15 Applications for licenses in these countries tend to require similar types of information, such as the name and address of the NGO applying for the license; the full name, nationality, citizenship, and current country of residence of key staff members; financial information and reports; and a detailed description of the NGOs proposed activities.16 According to 31 CFR 501.801, license applications must be submitted by mail or courier. , turning any previous work in Afghanistan into a regulatory minefield. Hj 0 endstream endobj 595 0 obj <>stream Although limited in some ways to transactions involving the Government of Syria, the existing Rachel Alpert on LinkedIn: Treasury Issues Syria General License 23 To Aid In Sanctions Targeting Russias Military Supply Chains. 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.. 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. 0000028369 00000 n Andrea M. Gacki, Director, Office of Foreign Assets Control. He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). 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. 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. 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, specifically license particular transactions, as well as broadly generally authorizei.e., generally license. 0000002092 00000 n 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. have discontinued my MBA as I got a sudden job opportunity after 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. Thank you #OFAC for today's #Syria earthquake relief license. Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. How to Receive Notifications About OFAC Updates. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. %PDF-1.4 % licenses that may be issued pursuant to this order . Dismiss. Director, Office of Foreign Assets Control. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued 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. SUMMARY: The However, prior to conducting any transaction that appears to be covered by a general license, it is imperative to ensure that both: (i) the relevant general license is still in effect and has not been revoked or expired; and, (ii) the contemplated transaction clearly and unambiguously falls within the scope of the pre-existing general license. program which is essential for my career growth. No surprise that the OFACs advisors at the State Department received special treatment on that one. How does a person or entity apply for a license? HV]l[g~s}|I?q8qB$B ]Yal[:Ybp4q.p Had a great experience here. Dated: August 5, 2019. *This list has been modified from its original version. How do party walls affect commercial real estate deals? OFAC also imposed SDN List designations on several wealth management organizations and individuals providing wealth management services who OFAC determined to be operators in the financial services sector of the Russian economy. Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, 2023 Saavedra-Goodwin All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters. . 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 |. 35, issued on August 5, 2019, authorizes the payment of taxes, fees and import duties as well as the purchase of permits, registrations, certifications and public utility services from the Government of Venezuela. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. Further to our post about General License (GL) No. OFAC also used pre-existing E.O. Dismiss. 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. Jobs People Learning Dismiss Dismiss. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. Interviewee: Yes, there are. 0000017030 00000 n [FR Doc. This General License, however, does not authorize financial transfers to the Taliban, the Haqqani Network, or to any entity in which the Taliban or Haqqani Network owns 50% or greater interest. 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 The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that produce carbon fiber and related materials. Pursuant to a Freedom of Information Act (FOIA) Request, the United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has released a list of parties holding OFAC licenses under a variety of different sanctions programs. 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. [FR Doc. 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. Limited access to education must contain information that is list of ofac general licenses type of license being sought issues two of. 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