5A, which was updated on October 24, 2019, authorizes various transactions and dealings with Petrleos de Venezuela, S.A. on or after January 22, 2020. However, these FAQs also advised that OFAC will not target persons for sanctions designations pursuant to this new Directive when those persons supply of goods and services to the metals and mining sector of the Russian Federation economy is solely for the safety and care of personnel, protection of human life, prevention of accidents or injuries, maintenance or repair necessary to avoid environmental or other significant damage, or activities related to environmental mitigation or remediation. Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. Persons or entities seeking to engage in an otherwise prohibited activity may submit an application for a license to OFAC. ACTION: Publication of web general licenses. 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. I was in search of an online course; Perfect e Learn For instance, just because you dont need a license to receive payment from a party designated under E.O. Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program used pre-existing E.O. 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. 0000003566 00000 n Recently, there has been yet step in the evolution of these authorizations. Although, these transactions are permitted for the payment of taxes, fees, import duties, purchase or receipt of permits, or public utility services, provided that such payments do not involve luxury items or services. Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian 13382. Director, Office of Foreign Assets Control. 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. 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. .12. ACTION: Publication of web general licenses. 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. 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. . 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. OFACs latest round of sanctions targets multiple Russian industries including, mining and metals, the financial sector, military supply chain, the aerospace industry, and the technology and electronics industries. OFAC issues two types of licenses general and specific and all license applications must contain information that is specific type of license being sought. 0000016532 00000 n Call Us At (954) 767-6333. xJx That license was applied for on August 4, 2011 and was received on August 11, 2011. 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. 560.211. 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 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 Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. Dated: August 5, 2019. ACTION: Publication of web general licenses. 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. 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. While many of these general licenses look to be identical, there are certain differences between them. 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. of International Grantmaking, The How to? of Domestic Grantmaking. This was recorded before the Paul Carroll no LinkedIn: New OFAC General Licenses for Humanitarian Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. 0000028369 00000 n This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian December 23, 2021 Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. 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 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). provided in . WebOffice of Foreign Assets Control U.S. Department of the Treasury Treasury Annex 1500 Pennsylvania Avenue, NW Washington, DC 20220 Attn: Licensing Division It is 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.. HK1)rd*4 =6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| Each sanctions program has a unique legal and regulatory framework that establishes the exact parameters of the sanctions. Thank you #OFAC for today's #Syria earthquake relief license. 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. 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.. 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. Our online courses offer unprecedented opportunities for people who would otherwise have limited access to education. 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. One of the areas OFAC has traditionally used their discretion to generally license is the provision of legal services to or on behalf of blocked persons or sanctioned jurisdictions. 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. 13224.. W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx 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. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. Digital Forensics. A general license authorizes a particular type of transaction for a class of persons without the need to apply for a license.9 A specific license is a written document issued by OFAC to a particular person or entity, authorizing a particular transaction in response to a written license application.10 The Code of Federal Regulations (CFR) is the collection of regulations setting out how the executive branch will interpret the parts of the U.S. Code that Congress charged it with enforcing. 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 |. Sanctions programs may be either comprehensive or selective. exams to Degree and Post graduation level. 0000004586 00000 n At the time the ITSR was issued, the regulations typically required specific license authorization to allow payments from blocked persons for generally authorized legal services provided to that blocked person. 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, 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. 60 to authorize wind down and rejection transactions through May 25, 2023 involving certain financial institutions blocked on February 24, 2023, and (iii) the issuance of General License No. 0000001176 00000 n 0000035570 00000 n Photography by Steve Evans, unless otherwise noted. of International Grantmaking. Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols.
