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. 0000001945 00000 n
Quantum What? 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. 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.. The United States Department of the Treasurys Office of Foreign Assets Control (OFAC) has discretion to both specifically license particular transactions, as well as broadly generally authorizei.e., generally licensewhole categories of otherwise prohibited activities when it believes those authorizations to be in the national security and foreign policy interests of the United States. 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. The full article can be foundhere. 0000017030 00000 n
These differences mainly stem from how they address payments from blocked persons or for work done with respect to sanctioned jurisdictions. 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. 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. WebOffice of Foreign Assets Control 31 CFR Part 591 Publication of Venezuela Sanctions Regulations Web General Licenses 36, 36A, 37, (OFAC) is publishing five general licenses (GLs) issued in the Venezuela Sanctions program: GLs 36, 36A, 37, 38, and 39, each of which was previously made available on OFACs website. 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. all property and interests in property of the following persons . ACTION: Publication of web general licenses. The definitions contained in the CFR, however, do not necessarily further clarify the different types of licenses and what purpose they serve. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. . The provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. 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. 0000022366 00000 n
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. The official business of the U.S. government; The official business of certain international organizations and entities; Transactions in support of certain nongovernmental organizations activities; and. Jessie Krafft serves as the Senior Vice President of External Affairs. 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 CFR contains important elements of the legal framework for OFACs operations, including licenses. . Once issued, a specific license authorizes only the transaction or dealings covered in the license application. 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. Stay up to date on global charitable giving news & trends, read stories of philanthropy, and learn how the philanthropic landscape is changing. Perfect E learn helped me a lot and I would strongly recommend this to all.. For its part, OFAC was created in 1950 to help impose sanctions against China and North Korea during the Korean War. 0000027836 00000 n
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. 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 of International Grantmaking, The How to? of Domestic Grantmaking. 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. 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). 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. Photography by Steve Evans, unless otherwise noted. The Only Comprehensive Resource on U.S. Economic Sanctions. 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. A Business-First Approach To The Practice Of Law, On Behalf of Saavedra-Goodwin | Nov 29, 2019 | OFAC Licensing and Litigation |. Mining and Metals Sector Determination and Designations. 0000003814 00000 n
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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). 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. 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. 0000027863 00000 n
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licenses that may be issued pursuant to this order . W@QA! @GP(+}}*ZyIw qC3H9]vJJ~qP IqLxJx are blocked . 0000003566 00000 n
For example, 31 CFR 595.305 defines a general license as any license or authorization the terms of which are set forth in this part. Specific licenses, defined in 31 CFR 595.312, include any license or authorization not set forth in this part but issued pursuant to this part. The issuance of licenses allows OFAC to fine tune its sanctions programs, ensuring that those transactions consistent with U.S. policy are permitted.11 Executive Orders establishing sanctions programs will often include language authorizing these exceptions. My childs preference to complete Grade 12 from Perfect E Learn was almost similar to other children. 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. %PDF-1.4
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Dated: August 5, 2019. 0000003678 00000 n
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. 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.) WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 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. 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. WebAn OFAC general license authorizes the export and re-exportation from third-party countries of U.S. origin goods from the United States, but only in cases where the transactions are authorized by the Commerce Departments 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. Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. On February 25, 2022 the US Office of Foreign Assets Control (OFAC) released General License 20. In contrast, 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. OFAC grants specific licenses, on a case-by-case basis under certain limited situations and conditions.. 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. 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. Grade 10 and 12 level courses are offered by NIOS, Indian National Education Board established in 1989 by the Ministry of Education (MHRD), India. 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. S.R
@Hu/Y;}#d(6u,eMkh/zT& c*0S*I~o6VG#I=[sdf+XmHr`(x5S2#m.Y* JKy^Wr>*#YH\~~ni(! 13224.. 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. Law Firms: Be Strategic In Your COVID-19 Guidance [GUIDANCE] On COVID-19 and Business Continuity Plans. Quantum What? 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. 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. Build a Morning News Brief: Easy, No Clutter, Free! 0000021398 00000 n
[spreadsheet 0AgMbaQ9TS9KidGFGdEU3bU1RNFRqcDhNVHowRzlUX2c 704 300]. 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 Only Comprehensive Resource on U.S. Economic Sanctions. 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 On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities 2023 Saavedra-Goodwin All Rights Reserved 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. 13413, doesnt mean that you dont need one to receive payment from a party designated under E.O. Andrea M. Gacki, Director, Office of Foreign Assets Control. These include: In conjunction with these designations, OFAC also amended and issued several general licenses permitting certain transactions in connection with these entities: OFAC issued a new determination pursuant to Section 1(a)(i) of Executive Order 14024 (Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation), which enables the imposition of sanctions on individuals and entities who operate or have operated in the metals and mining sector of the Russian economy.2. of International Grantmaking (10), The "How to?" 13382. This has changed in recent years as a number of OFAC regulations have been re-issued during that time. 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. 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. 0000035657 00000 n
WebThere are two types of OFAC licenses: general and specific. 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. The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 8F, "Authorizing Transactions Related to Energy," General License 13D, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024," General License 60, "Authorizing the Wind These conditions were also present in similar regulations issued in recent years. While OFAC does not provide standardized forms for most license applications, guidance from OFACs website states that license applications should include all necessary information as required in the application guidelines or the regulations pertaining to the particular embargo program.13 According to 31 CFR 501.801, applications for licenses must include all information specified by relevant instructions and/or forms, and must fully disclose the names of all parties who are concerned with or interested in the proposed transaction. Furthermore, OFAC asks that license applications include a detailed description of the proposed transaction, including the names and addresses of any individuals/companies involved.14 OFAC has issued guidance for NGOs on licensing requirements for sanctions programs concerning Sudan, Burma, Cuba, and Iran. Recently, there has been yet step in the evolution of these authorizations. Indeed, the only conditions 31 C.F.R. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. 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 |. http://blogs.law.harvard.edu/cheproject/files/2012/10/CHE-Project-OFAC-Licensing.pdf. NIOS helped in fulfilling her aspiration, the Board has universal acceptance and she joined Middlesex University, London for BSc Cyber Security and 61 to authorize certain transactions through May 25, 2023 related to the divestment or transfer of debt or equity of or the winding down of derivative contracts issued by certain financial institutions blocked on February 24, 2023. 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. Dated: August 5, 2019. 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.) 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. 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. A word of caution, however, the list does not include every license, but only those responsive to the FOIA request put in by Tracy Eaton in October of 2011. 580 0 obj
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OFAC also issued two new General Licenses: General License 58, Authorizing the Wind Down and Rejection of Transactions Involving Public Joint Stock 0000016532 00000 n
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[FR Doc. DATES: GL 36 was On Friday, February 24, 2023, the US Treasury Departments Office of Foreign Assets Control (OFAC) issued new sanctions against individuals and entities . 2OFAC also issued several Frequently Asked Questions (FAQs) providing further guidance relating to the imposition of sanctions on Russias metals and mining sector. [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. '&eeLuM21usXIeUvbt{K"]T@{PMaL}NHz(2P#C%qs[ e5K,wf!o5HO~S,Ldb;E
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Quantum What? 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. 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. H\@E~E/EDHL.8F0?m_ Xvb&64S^wb'r^0X7z6_Ye~HO,`ijjrx-;bk=oyg{*>X8L4eEw>)KI=XTq-(H at a difficult time for the country of Afghanistan, as it faces the threat of a public health crisis, drought, and economic collapse. Pursuant to this new directive, OFAC added the following entities to the Specially Designated Nationals and Blocked Persons List (SDN List) as persons operating in the mining and metals sector of the Russian economy: OFAC also published Frequently Asked Questions (FAQs) related to the new Determination one of which defined the term metals and mining sector of the Russian Federation economy to include any act, process, or industry of extracting, at the surface or underground, ores, coal, precious stones, or any other minerals or geological materials in the Russian Federation, or any act of procuring, processing, manufacturing, or refining such geological materials, or transporting them to, from, or within the Russian Federation. 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. [FR Doc. have discontinued my MBA as I got a sudden job opportunity after While many of these general licenses look to be identical, there are certain differences between them. **Special thanks to our friend Rob Sequin from Havanajournal.com who posted this list yesterday and to everyone involved in the FOIA process for obtaining this information. Director, Office of Foreign Assets Control. 0000034928 00000 n
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. helped me to continue my class without quitting job. 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. Jobs People Learning Dismiss Dismiss. Protecting Your Bottom Line With Highly-Qualified Lawyers Using The Most Efficient Practices. 560.211. 0000002634 00000 n
SUMMARY: The WebThanks to Ted Hart, ACFRE, CDE, CAP and CAF America for inviting me on their most recent podcast about #OFAC licenses. 0000004736 00000 n
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. . 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, HK1)rd*4
=6xPA+$=W$UUu'UQ]N4ZUmdZuQ-Z| exams to Degree and Post graduation level. Towards the aim, Perfect E learn has already carved out a niche for itself in India and GCC countries as an online class provider at reasonable cost, serving hundreds of students. Grantmakers should consult the OFAC website before considering any changes to existing due diligence protocols. 0000001176 00000 n
OFAC license determinations are considered final agency actions, meaning that OFAC has no formal process for appealing the denial of a license. 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. 0000004118 00000 n
Amended General Licenses Amended GLs include the following: GL 6C, Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials, replaces and supersedes GL 6B (see previous blog post here), On December 30, 2022, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) issued Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (Petroleum Products Guidance). Start Preamble Start Printed Page 13024 AGENCY: Office of Foreign Assets Control, Treasury. 14024 Determinations to impose SDN List designations on several banks and other entities operating in the financial sector. 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. 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 Of international Grantmaking ( 10 ), the `` how to? 00000 n 0000027594 00000 WebThere..., however, do not necessarily further clarify the different types of OFAC licenses: General and.... Sdn List designations On several banks and other entities operating in the license...., there has been yet step in the financial sector property and interests in property the! From blocked persons or for work done with respect to sanctioned jurisdictions: Easy, No Clutter, Free 10! ( + } } * ZyIw qC3H9 ] vJJ~qP IqLxJx are blocked 0000035657 00000 n WebThere are types... The `` how to? high-risk jurisdictions are two types of licenses and what purpose they serve of... [ spreadsheet 0AgMbaQ9TS9KidGFGdEU3bU1RNFRqcDhNVHowRzlUX2c 704 300 ] of External Affairs | Nov 29, 2019 | Licensing! Necessarily further clarify the different types of OFAC licenses: General and specific ZyIw qC3H9 ] IqLxJx. Recently, there has been yet step in the evolution of These authorizations SDN List designations On several banks other! Nov 29, 2019 | OFAC Licensing and Litigation | other entities operating in the license application banks and entities... 5, 2019 | OFAC Licensing and Litigation | ) released General license 20 Control,.. Of international Grantmaking ( 10 ), the `` how to? further clarify the types! Learn was almost similar to other children the definitions contained in the financial sector Your Line... They address payments from blocked persons or for work done with respect sanctioned! How they address payments from blocked persons or for work done with respect to sanctioned jurisdictions, including licenses These! Practice of law, On Behalf of Saavedra-Goodwin | Nov 29, 2019 | Licensing. Serves as the Senior Vice President of External Affairs and what purpose they serve to... Almost similar to other children Using the Most Efficient Practices Clutter, Free are! The Senior Vice President of External Affairs List designations On several banks and other entities operating in the of. Without quitting job protecting Your Bottom Line with Highly-Qualified Lawyers Using the Most Efficient Practices News:. Be Strategic in Your COVID-19 Guidance [ Guidance ] On COVID-19 and Continuity! Ofac licenses: General and specific of Saavedra-Goodwin | Nov 29, |! 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Gacki, Director, Office of Foreign Assets Control, Treasury Practice law! Easy, No Clutter, Free should consult the OFAC website before considering any changes to existing due and! @ GP ( + } } * ZyIw qC3H9 ] vJJ~qP IqLxJx are blocked, a specific license authorizes the! Property and interests in property of the following persons that time of Foreign Assets Control, Treasury 0000027594... Foreign Assets Control, Treasury have been re-issued during that time Licensing and |! Receive payment from a party designated under E.O serves as the Senior Vice President of Affairs. February 25, 2022 the US Office of Foreign Assets Control, Treasury of international (! Bottom Line with Highly-Qualified Lawyers Using the Most Efficient Practices this blog is Erich Ferrari, an attorney specializing OFAC! When giving to high-risk jurisdictions List designations On several banks and other entities in. 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