develop their business skills and accelerate their career program. 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. These new General Licenses (GL 14, 15, 16, 17, 18, & 19) allow for specific business dealings with entities that are tied to the Taliban and the Haqqani Network, both of which are Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 and many of whose members are also found on on the SDN list. 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). 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. . 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. SPECIALLY DESIGNATED NATIONALS LIST UPDATE The following individuals have been added to OFAC's SDN List: HWANG, Kil Su (Korean: ), Congo, Democratic Republic of the; DOB 09 Dec 1973; POB Pyongyang, North Korea; nationality Korea, North; Gender Male; Secondary sanctions risk: North Korea Sanctions What is interesting, however, is that OFAC has not remained consistent in implementing the change from quarterly to annual reporting under these types of authorizations. Incidentally, there license has no expiration date. 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. 0000016532 00000 n The complete list of OFACs February 24, 2023 additions to the SDN List can be found here. [FR Doc. I strongly successful learners are eligible for higher studies and to attempt competitive 0000003952 00000 n . 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. But, our concern was whether she could join the universities of our preference in abroad. 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. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here. 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. 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. Newer sanctions regulationssuch as the DRCSR and the Global Magnitsky Sanctions Regulations (GMSR)however only impose an annual reporting requirement. 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. lPbB. 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. 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. Our online courses offer unprecedented opportunities for people who would otherwise have limited access to education. These conditions were also present in similar regulations issued in recent years. 14024) which authorizes OFAC to impose blocking sanctions on any person operating in the metals and mining sector of the Russian Federation economy. 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. Once issued, a specific license authorizes only the transaction or dealings covered in the license application. Reporting requirements with respect to general or specific licenses for payment of professional fees from unblocked sources related to the provision of generally authorized legal services to blocked persons have also evolved over recent years. in KSA, UAE, Qatar, Kuwait, Oman and Bahrain. OFAC noted that these broad, sweeping sanctions will further isolate Russia from the international economy and hinder Russias ability to obtain the capital, materials, technology, and support that sustain its war against Ukraine. WebThere are two types of OFAC licenses: general and specific. 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). 0000027327 00000 n Call Us At (954) 767-6333. Mining and Metals Sector Determination and Designations. 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. Jobs People Learning Dismiss Dismiss. The provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. Many countries facing ongoing disasters and humanitarian emergencies also continue to face broad-ranging sanctions that grantmakers must still comply with. 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. 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. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. Nor does this General License permit financial transactions involving any blocked individual who is in a leadership role of a governing institution in Afghanistan. Emerge as a leading e learning system of international repute where global students can find courses and learn online the popular future education. OFAC imposed SDN List designations on the following individuals and entities for their roles in helping Russia: Russian Elite-Linked Businessman Tied to Illicit Financial Activity. WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 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. . 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. hb```b``} @1v mGlx~]qjV9iu2\=cO^nNE The recent tranche of sanctions also targeted Russias military supply chains, including Russian entities that produce carbon fiber and related materials. How does a person or entity apply for a license? The most important ones pertain to banks that might be holding blocked funds belonging to a designated person. H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. 0000035570 00000 n Dismiss. 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 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. This was recorded before the Paul Carroll on LinkedIn: New OFAC General Licenses for Humanitarian 0000001945 00000 n She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding. For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. 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. 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 Mint Office of Inspector General(OIG) Treasury Inspector Generalfor Tax Administration (TIGTA) Special Inspector General, Troubled Asset Relief Program Traditionally, OFAC required payments made under those types of licenses both (general and specific) to be reported to the Licensing Division on a quarterly basis. 0000028289 00000 n http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. In addition, the Global Terrorism Sanctions Regulations (GTSR)which governs dealings with parties designated under E.O. 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.) Quantum What? , turning any previous work in Afghanistan into a regulatory minefield. The following activities are covered: See a full factsheet on the Afghanistan General Licenses on the OFAC website here. 0000035177 00000 n Build a Morning News Brief: Easy, No Clutter, Free! The most important ones pertain to banks that might be holding blocked funds belonging 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. Brooks Reed is CAF America's Vice President of Business Development, a role in which he oversees Business Development, Communications, and Content Development. . Photography by Steve Evans, unless otherwise noted. H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H 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?" OFAC also issued an updated guidance document relating to the price cap policy for Russian crude oil and petroleum, On February 9, 2023, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) issued Syria General License 23, Authorizing Transactions Related to Earthquake Relief Efforts in Syria. General License 23 authorizes transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations (SySR) through 12:01 p.m. eastern daylight time, August 8, 2023. Charity & Security Network, a fiscally sponsored project of NEO Philanthropy, Inc. The database also reveals a lot of interesting information. Weblist of ofac general licenses. For years, organizations and individuals have been asking for a whitelist of entities who hold valid OFAC licenses. 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. Digital Forensics. OFAC has the authority both to enforce these laws, by freezing the assets of any U.S. group or individual who violates them, and to provide exceptions to these laws through licenses. Photography by Steve Evans, unless otherwise noted. 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. For additional information on that announcement and its implications, see our separate blog post. 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 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. Today, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) released a set of new and updated General Licenses that authorize four types of broad-ranging activities supporting much-needed humanitarian aid and assistance. If authorized legal services are provided to those parties, then the payment for those services or reimbursement for any incurred expenses must be specifically licensed or comply with 31 C.F.R. Had a great experience here. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. 202304360 Filed NIOS helped in fulfilling her aspiration, the Board has universal acceptance and she joined Middlesex University, London for BSc Cyber Security and Interviewee: Yes, there are. 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. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. Sanctions programs may be either comprehensive or selective. are blocked . 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. 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 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. 0000028369 00000 n 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. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. Andrea M. Gacki, Director, Office of Foreign Assets Control. 13224 and contains a general license authorization allowing payments for the provision of generally authorized legal services from unblocked sourcesalso maintains a quarterly reporting requirement. Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime. SDNs, creditors and other entities can apply for general licenses from OFAC; and, once a general license has been approved, it is non-specific to the applicant. I Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. 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. 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. 13224., Along with this recent issuance, OFAC has published. DATES: GL 36 was 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. Jobs People Learning Dismiss Dismiss. 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