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. The Only Comprehensive Resource on U.S. Economic Sanctions. 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). Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. successful learners are eligible for higher studies and to attempt competitive 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. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here. . WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 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 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. . 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. 0000002748 00000 n 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. 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. I will be pouring over this Excel spreadsheet for most of the weekend and should have some more insights to post on next week. of International Grantmaking, The How to? of Domestic Grantmaking. Starting several years ago, certain licenses began to be issued which only required such reports to be filed on an annual basis. She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding. Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx 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. OFAC administers and enforces economic sanctions against countries and individuals, including those persons and entities designated as terrorists. The Office of Foreign Assets Control (OFAC) within the U.S. Department of Treasury is tasked, in part, with ensuring that money from U.S. persons and entities does not fall into the hands of terrorist groups. Similarly, OFAC used pre-existing E.O. exams to Degree and Post graduation level. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policywho advise OFAC on license applicationsapplied for a license on behalf of Citigroup under the new Libya Sanctions program. 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. WebThere are two types of OFAC licenses: general and specific. 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. Many countries facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply with. Jobs People Learning Dismiss Dismiss. 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. Educational programs for all ages are offered through e learning, beginning from the online This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian 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. Director, Office of Foreign Assets Control. . 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. Quantum What? 0000003814 00000 n The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. provided in . Once issued, a specific license authorizes only the transaction or dealings covered in the license application. . lPbB. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. 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. in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. Thus, it is important to read the regulations carefully each time you take on a legal representation for or on behalf of a blocked person, as the authorizations for payment, and the reporting requirements with respect to those payments vary from program to program and have been changing as new regulations are issued. 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. 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.. All U.S. persons (including all U.S. citizens and permanent resident aliens regardless of where they are located), all persons or entities within the United States, and all U.S. incorporated entities and their foreign branches must comply with OFAC regulations. WebOn August 6, 2019, the U.S. Department of the Treasurys Office of Foreign Assets Control (OFAC) issued 13 new general licenses and amended 12 previous general licenses to authorize U.S. persons to continue engaging in a range of narrowly defined transactions involving Venezuelas government. 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. By issuing General License J-1, OFAC has started to provide its answer, as this particular He is a Chartered Advisor in Philanthropy (CAP) and certified in Anti-Money Laundering by the Society of Trust and Estate Practitioners (STEP). 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. 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. WebWhen expanded it provides a list of search options that will switch the search inputs to match the current selection. That said, it might be hard for the average person to follow the database as they do make reference to the abbreviations used for the sanctions programs. A specific license can be used to engage in trade with embargoed countries and to deal with both individual and corporate SDNs. U"20 Pyy~jVq{1I)~|$uw^SHD S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! Quantum What? 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 Dated: August 5, 2019. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. 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). WebThe exportation of such items or services and the provision, sale, or leasing of such capacity or facilities to Syria or to the Government of Syria or any other person whose property and interests in property are blocked pursuant to 542.201 (a) are prohibited. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. Jessie Krafft serves as the Senior Vice President of External Affairs. 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. 0000002092 00000 n For example, specific licenses issued under the Foreign Narcotics Kingpin Sanctions Regulations (FNKSR) for payments related to the provision of legal services to parties blocked under the Foreign Narcotics Kingpin Designation Act (Kingpin Act) now only require annual reports to made on an annual basis. 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 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. WebThe United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has discretion to both specifically license particular transactions, as well as We follow a systematic approach to the process of learning, examining and certifying. 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