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, provided in . MBA is a two year master degree program for students who want to gain the confidence to lead boldly and challenge conventional thinking in the global marketplace. 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 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 license was granted under the Global Terrorist Sanctions Regulations and also has no expiration date. 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. 0000021988 00000 n General License 8 General License 8 permits Chevron, Halliburton, Schlumberger, Baker Hughes, and Weatherford International to engage in certain dealings otherwise prohibited by the PdVSA designation until July 27th, 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. Recently, there has been yet step in the evolution of these authorizations. 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. 0000034928 00000 n .12. 0000035570 00000 n 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. . Further to our post about General License (GL) No. Build a Morning News Brief: Easy, No Clutter, Free! As the U.S. Department of the Treasury explains, [a] general license authorizes a particular type of transaction for a 2023 Saavedra-Goodwin All Rights Reserved 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. 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. For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. SUMMARY: The 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. 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.. of International Grantmaking. 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.. Alternative Dispute Resolution And Mediation Services. 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. CAF America also encourages all grantmakers to review OFAC documents stating that the property and interests in property of an entity are blocked if one or more blocked persons own, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest in the entity, whether or not the entity itself is incorporated into the [SDN List]. This highlights the importance of high-quality due diligence and commitment to regulatory compliance in international philanthropyespecially when giving to high-risk jurisdictions. These General License issuances and amendments included (but were not limited to): (i) the amendment of General License No. Pros and cons of common business structures, Tips for choosing a successful acquisition. M_;C}EZrB"F${#4eq3mI4\/X|L@# XruR {WzGc d>dx%o%fjn,Vvoy{"i )u (@!%d%@B x@ hHk XD O8xo0]`{mPp}`lC]x'08k07x|AAkFA,"|=>f{nvO~! The provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. Note 1 to paragraph ( b ) (3) of 542.211: How do party walls affect commercial real estate deals? Dated: August 5, 2019. I was in search of an online course; Perfect e Learn S.R @Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities operating in Russia and against those assisting with Russias war efforts in Ukraine. 0000022436 00000 n 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: For an overview of the impact of OFACs Russia sanctions, FACT SHEET: Disrupting and Degrading One Year of U.S. Sanctions on Russia and Its Enablers. successful learners are eligible for higher studies and to attempt competitive test, which makes it an ideal choice for Indians residing Insider Blog | Cross-Border & Domestic Giving, The How to? of Domestic Grantmaking (2), The "How to?" WebFurther to our post about General License (GL) No. 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, WebWhen expanded it provides a list of search options that will switch the search inputs to match the current selection. 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). 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. Photography by Steve Evans, unless otherwise noted. 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. Dismiss. 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. 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. 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. 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. 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. 0000022516 00000 n 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. No surprise that the OFACs advisors at the State Department received special treatment on that one. 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 H4$`CN(?miw]';y#6L"eV1/>y~Z^}8K'?\~HBo)..K_#DRsO[oIhesE~=c704IT>K,wL_Db ^|5fq$(L1JctD;wIdUKuR1Zvi{M%35n$Fb2. 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.) 0000001176 00000 n For instance, OFAC states that it may conduct background investigations of each owner, significant shareholder, director, manager, and other key employee [sic] that will be directly involved in the applicants Cuba-related business.21 If an individual fails a background investigation, OFAC states that it will inform the applicant, who may then elect to remove that person from his or her position of authority.22. Through this role, she is responsible for organizational knowledge management and original content creation pertaining to international philanthropy and cross-border giving. 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