722. NOTE: You should not renew your license until you are able to confirm that you meet the continuing education requirements for your specific licensure. In 2021, the U.S. has a long list of countries under U.S. sanctions, from the Balkans to Zimbabwe. OFAC usually has the authority by means of a specific license to permit a person or entity to engage in a transaction which otherwise would be prohibited. Any applicant or other party in interest desiring to present additional information may do so at any time before or after OFAC makes its decision with respect to the application. IF A SPECIFIC LICENSE WAS ISSUED AS A RESULT OF WILLFUL MISREPRESENTATION ON THE PART OF THE APPLICANT OR HIS AGENT, IT MAY, AT THE DISCRETION OF THE SECRETARY OF THE TREASURY, BE DECLARED VOID FROM THE DATE OF ITS ISSUANCE, OR FROM ANY OTHER DATE. This process will be necessary for each IP address you wish to access the site from, requests are valid for approximately one quarter (three months) after which the process may need to be repeated. (6) Rules governing availability of information. U.S. Department of the Treasury. Programs administered by OFAC have included sanctions on Iran, North Korea, Cuba, Syria, and Russia. FORMS FOR LICENSE APPLICATIONS: 180 hours Chemical Dependency Specific Education - can be completed with college courses and/or CEU certificates from Board approved authorized entities. WASHINGTON Today, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated four companies generating revenue from, and contributing to, the conflict in Sudan. The Volkov Law Group var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); | Attorney Advertising, Copyright var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); JD Supra, LLC. OFAC has determined that this issue is outside of its control. To apply for a specific license, it is not required that a particular form be utilized. For example, if the agency denies the application, someone can appeal it in federal court or they can revise and refile their license application if they have new information for OFAC to consider. (b) Specific licenses(1) General course of procedure. Before sharing sensitive information, make sure youre on a federal government site. The process is substantially similar to preparing a request for interpretive guidance, where someone gathers the information regarding the proposed transaction first. If you encounter issues with the application, please reattempt submission with Microsoft Edge before contacting IT Support. Message & data rates may apply. Treasury Annex Applicants may be required to furnish such further information as is deemed necessary to assist OFAC in making a determination. 1592 AND 1595A, 18 U.S.C. Depending on the transaction they want to engage in, an individual should have supporting documentation that substantiates and supports what they want to do and why they want to do it. Since OFAC communicates with applicants via email, OFAC recommends that applicants include an alternative email address in their applications if they normally use the 126.com or 163.com email provider. Most license applications do not have to be submitted on a particular form. Federal government websites often end in .gov or .mil. Which individuals may be transported between the United States and Cuba by a person that qualifies for the general license to provide carrier services? However, OFAC will reconsider its determinations for good cause, for example, where the applicant can demonstrate changed circumstances or submit additional relevant information not previously made available to OFAC. Parts 730 et seq., administered by the Department of Commerce, and the International Traffic in Arms Regulations, 22 C.F.R. OFACs efforts on this front could reduce the groups ability to support the training of new recruits and the acquisition of weapons. Specific license applications are reviewed by OFAC on a case by case basis. Answer Yes, provided the underlying remittance transactions are authorized under 31 CFR 515.570 of the Cuban Assets Control Regulations (CACR) and the digital payment service provider is a U.S.-registered money transmitter or other qualifying banking institution within the definition of that term provided in 31 CFR 515.314. 725. SUMMARY: The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing a general license (GL) issued pursuant to the Iranian Transactions and Sanctions Regulations and Executive Order 13846, GL O, which was previously made available on OFAC's website. "Sanctions Programs and Country Information. License applications submitted to OFAC and specific licenses issued by OFAC are subject to the FOIA and generally will be released upon the receipt of a valid FOIA request, unless OFAC determines that such information should be withheld in accordance with an applicable FOIA exemption. Russia moved troops into the two separatist regions of eastern Ukraine and engaged in military operations throughout the country. ", U.S. Department of the Treasury. A COPY OF THIS APPLICATION AND ALL RELATED DOCUMENTATION MUST BE RETAINED BY THE APPLICANT FOR AT LEAST FIVE YEARS AFTER THE DATE OF THE UNDERLYING TRANSACTION. OFAC permits two format options for submitting TSRA license applications: online or hard-copy, though we highly recommend the use of OFACs online application portal. The agencys actions are usually authorized by Congressional legislation. (ii) Information to be supplied. Click on "New License Applications" 3. These include white papers, government data, original reporting, and interviews with industry experts. International COVID-19 Stimulus and Relief, National Defense Authorization Act for FY 2023. No. Application for the release of a wire transfer blocked at a U.S. financial institution, Application for a specific license or interpretive guidance in all other circumstances (Transactional), Application to export agricultural commodities, medicine, or medical devices to Sudan or Iran pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA). OFAC cited several deficiencies in Murads compliance efforts, including the absence of a specific sanctions compliance program, high-level executive participation in illegal conduct, and the absence of any compliance structure in relation to the specific sanctions risks Murad faced. An official website of the United States government. By submitting your mobile number, you agree to receive text messages from regarding your subscriptions or other industry related information. In May 2015, Executtive-1 signed a new distribution agreement with the same Iran distributors CEO for a related UAE-based company to become Murads sole distributor in the Middle East. Instead, you can save a copy of the application in progress by selecting the Export button on the top left corner of each page and save the Microsoft Excel file to your computer. To apply for a license, click the link below or scroll down for more information on the different licensing categories. The mailing address for license applications is: In order to apply for a specific license to release blocked funds, you are encouraged to file an electronic application to have blocked funds released by visiting the following link: https://ofac.treasury.gov/ofac-license-application-page. ", U.S. Department of the Treasury. Bureau of Industry and Security U.S. Department of Commerce 1500 Pennsylvania Avenue, NW During this interim period, Murad submitted another application to OFAC for a specific license to export its products to Iran. These are often carried out in cooperation with allied nations. A COPY OF THIS APPLICATION AND ALL RELATED DOCUMENTATION MUST BE RETAINED BY THE APPLICANT FOR AT LEAST FIVE YEARS AFTER THE DATE OF THE UNDERLYING TRANSACTION. Persons engaging in transactions pursuant to general or specific licenses must make sure that all conditions of the licenses are strictly observed. U.S. Department of the Treasury A license is an authorization from OFAC to engage in a transaction that otherwise would be prohibited. If you close your web browser before you have submitted your application, your changes will not be saved when you return. Applicants must first select the type of application that will be submitted from the following choices: OFAC has become aware that emails sent by OFAC to email addresses hosted by certain email service providers located outside the United States, including the 126.com and 163.com email providers, are not received by the intended recipients. A SPECIFIC LICENSE IS NOT TRANSFERABLE, IS LIMITED TO THE FACTS AND CIRCUMSTANCES SPECIFIC TO THE APPLICATION, AND IS SUBJECT TO THE PROVISIONS OF 31 C.F.R. 552) and the provisions of 31 CFR part 1. The transaction closed on September 1, 2015. Applicants must first select the type of application that will be submitted from the following choices: OFAC has become aware that emails sent by OFAC to email addresses hosted by certain email service providers located outside the United States, including the 126.com and 163.com email providers, are not received by the intended recipients. Persons availing themselves of certain general licenses may be required to file reports and statements in accordance with the instructions specified in those licenses. FOR PROVISIONS RELATING TO PENALTIES. 1001, 50 U.S.C. https://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/Programs.aspx. To this end, OFAC stated that senior executives with managerial responsibilities should take particular care to ensure awareness of applicable prohibitions by employees and refrain from [themselves] and prevent sanctions violations. If the application is filed by an agent, the agent must disclose the name of his or her principal(s). FOR PROVISIONS RELATING TO PENALTIES. An embargo is a government order that restricts commerce or exchange with a specified country, usually as a result of political or economic problems. Therefore, in order to prevent such delay, submit one application with one cover letter per envelope. Due to aggressive automated scraping of FederalRegister.gov and eCFR.gov, programmatic access to these sites is limited to access to our extensive developer APIs. OFAC views information submitted in furtherance of an application for a specific license pursuant to this paragraph (b) to be required information for purposes of Exemption 4 of the FOIA. You must agree to the Terms of Agreement. LICENSEES SHALL FURNISH AND MAKE AVAILABLE FOR INSPECTION ANY RELEVANT INFORMATION, RECORDS OR REPORTS REQUESTED BY THE SECRETARY OF THE TREASURY OR ANY DULY AUTHORIZED OFFICER OR AGENCY OF THE SECRETARY. "Foreign Interference in a United States Election Sanctions. An official website of the United States government. Our OFAC blocked asset attorneys frequently deal with unblocking application cases in order to release your funds back to you and complete the transaction. Persons engaging in transactions pursuant to general or specific licenses must make sure that all conditions of the licenses are strictly observed. Read on to learn more about what goes into applying for a specific license with OFAC, as well as the ways askilled OFAC lawyercould offer you their assistance today. Unlike a court case, when filing for a specific license there is no hearing. Unilever did not discover the conduct during its pre-acquisition due diligence of Murad. Form TDF 9022.54 may be obtained from OFAC's Reporting and License Application Forms page, or by mail at the address above. The offers that appear in this table are from partnerships from which Investopedia receives compensation. OFAC also issues specific licenses on a case-by-case basis under certain limited situations and conditions. A threat of sanctions currently exists against any nation or entity that seeks to interfere with a U.S. election. (2) Applications for specific licenses. PART 501, THE RELEVANT EXECUTIVE ORDER OR PART OF 31 C.F.R. The purpose of U.S. sanctions programs is to advance U.S. foreign policy objectives and protect national security. The State Department has always played a critical role in approving or denying license applications to OFAC that have foreign policy implications, as licenses for Russia, Iran, China . How Do OFAC Country-Based Sanctions Work. Both types of licenses are written authorizations by the Office of Foreign Assets Control to permit certain transactions with strict adherence to specific conditions put in place by OFAC. Applications for specific licenses to engage in any transactions prohibited by or pursuant to this chapter, or sanctions programs that have been otherwise delegated to the OFAC Director for implementation and administration, must be signed, either manually or electronically, and filed through OFAC's Reporting and License Application Forms page (https://licensing.ofac.treas.gov/) or, if that option is unavailable, by mail, addressed to the Office of Foreign Assets Control, Licensing Division, U.S. Department of the Treasury, 1500 Pennsylvania Avenue NW, Freedman's Bank Building, Washington, DC 20220. Application for the release of a wire transfer blocked at a U.S. financial institution, Application for a specific license or interpretive guidance in all other circumstances (Transactional), Application to export agricultural commodities, medicine, or medical devices to Sudan or Iran pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA). APP. To the extent that your proposed travel falls within the scope of an existing general license, you may proceed without applying for a specific license from OFAC. Then, from the first drop down box, select "Board of Pharmacy." From the second drop down box select "Pharmacy Technician Trainee." From the third drop down box select "General Application." 4. Answer the eligibility questions. 16, AND SECTION 701 ET SEQ. Applicants should submit only one copy of a specific license application to OFAC; submitting multiple copies may result in processing delays. Such requirements include the Export Administration Regulations, 15 C.F.R. Electronic Code of Federal Regulations (e-CFR), Subtitle BRegulations Relating to Money and Finance, CHAPTER VOFFICE OF FOREIGN ASSETS CONTROL, DEPARTMENT OF THE TREASURY, PART 501REPORTING, PROCEDURES AND PENALTIES REGULATIONS. Before applying for a specific license, please review the information about Cuba travel and the 12 categories of general licenses related to Cuba travel found in the Cuba Assets Control Regulations (31 CFR part 515). The sanctions may be approved by Congress or initiated by emergency powers held by the president. Finally, OFAC noted that the Murad case underscored the importance of pre- and post-acquisition due diligence and integration to identify and promptly remediate compliance deficiencies. 5. This compensation may impact how and where listings appear. "Imposing Certain Sanctions in the Event of Foreign Interference in a United States Election. During this interim period, Murad submitted another application to OFAC for a specific license to export its products to Iran. The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Iran-related General License P "Authorizing the Wind Down of Transactions Involving Navyan Abr Arvan Private Limited Company or Arvancloud Global Technologies L.L.C.". "Ukraine-/Russia-Related Sanctions. ATTENTION IS DIRECTED TO 19 U.S.C. There are two types of licenses: general licenses and specific licenses. If you want to request a wider IP range, first request access for your current IP, and then use the "Site Feedback" button found in the lower left-hand side to make the request. Unilever discovered Murads business activities in Iran on October 20, 2015, six weeks after the acquisition closed, when a Unilever US employee received an email sent from the UAE distributors CEO to a senior Murad executive, explaining the time it took for Murads products to reach Tehran from the United States. Iran is a significant US national security concern, so requests for Iran-related OFAC specific licenses will typically require US State Department concurrence. Murad never disclosed to Unilever its prior and ongoing business activities involving Iran. Most OFAC sanctions programs provide exemptions to their prohibitions for certain donated goods, such as articles to relieve human suffering. Please read all instructions and relevant information fully before submitting an application for a specific license. Interestingly, OFAC cited specifically Murads reporting line on sanctions compliance issues to personnel in Unilevers division in the United Kingdom. The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely. Since OFAC communicates with applicants via email, OFAC recommends that applicants include an alternative email address in their applications if they normally use the 126.com or 163.com email provider. Michael Boyle is an experienced financial professional with more than 10 years working with financial planning, derivatives, equities, fixed income, project management, and analytics. Executive-1 issued that instruction. Upon application submission you should see a confirmation page. As a condition for the issuance of any specific license, the licensee may be required to file reports with respect to the transactions authorized by the specific license in such form and at such times and places as may be prescribed in the license or otherwise. . If you close your web browser before you have submitted your application, your changes will not be saved when you return. This includes entities that stockpile weapons of mass destruction. To verify another OFAC document, please contact the OFAC Compliance Division at 1-202-622-2490. "Specially Designated Nationals and Blocked Persons List (SDN) Human Readable Lists. To verify a specific license, please contact the OFAC Licensing Division at 1-202-622-2480. You should also note that the Iranian Transactions and Sanctions Regulations authorize U.S. financial institutions and U.S.-owned or -controlled foreign entities to directly advise or confirm letters of credit issued by third-country banks for authorized shipments. OF THE RELEVANT PART OF 31 C.F.R. One of the most widely known sanctions is against Russia, ordered in response to the Russian incursion into Ukraine that began in 2014. After receiving an inquiry from Murads bank about specific payments involving Iran, Unilever again instructed Murad to advise the UAE distributor that it could not sell its products to Iran. Investopedia does not include all offers available in the marketplace. 715. As such, it is usually best practice to present their arguments to OFAC directly in the application and to cooperate with the agency as it makes its decision. "U.S. Treasury Announces Unprecedented & Expansive Sanctions Against Russia, Imposing Swift and Severe Economic Costs. You will be required to complete a questionnaire to identify whether you are eligible to access Okta applications from an embargoed territory and you can submit documentation verifying your OFAC specific license. During this interim period, Murad submitted another application to OFAC for a specific license to export its products to Iran. It is the policy of OFAC not to grant applications for specific licenses authorizing transactions to which the provisions of a general license are applicable. Do you have questions about traveling to Cuba? It is an application process that is filed either online or via mail through a letter to OFAC. Persons availing themselves of certain general licenses may be required to file reports and statements in accordance with the instructions specified in those licenses. When you return to complete and submit your application, upload the Excel document in the section below and select Begin to proceed with the application. ACTION: Publication of web general license. OFAC enforces U.S. trade and economic sanctions imposed on foreign nations or groups. These are called specific licenses. CHAPTER V. A LICENSE MAY BE REVOKED OR MODIFIED AT ANY TIME AT THE DISCRETION OF THE SECRETARY OF THE TREASURY. An official website of the United States government. The use of sanctions and other punitive trade policies are used to persuade a nation or group to change some behavior that is seen as detrimental to the international community. OFAC has determined that this issue is outside of its control. The DPRK conducts malicious cyber activities and deploys information technology (IT) workers who . Application for authorization to travel to Cuba under a specific license. Submit any necessary documentation. OFAC's predecessor was the Office of Foreign Funds Control (FFC), established in 1940 in response to the Nazi invasion of Norway. OFAC's regulations governing unblocking and release of blocked funds make it clear that " [a]ny person who is a party to the . In some situations, individuals need to close bank accounts they have in sanctioned countries or wind down economic activities involving a sanctioned target. Specific licenses also may be issued by the Secretary of the Treasury acting directly or through any specifically designated person, agency, or instrumentality. application of the exemptions or authorizations, or believe additional authorizations are needed, OFAC and BIS stand ready to engage with those stakeholders to provide guidance and respond to applications for specific licenses. 1001, 50 U.S.C. The U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") administers a number of different sanctions programs. Some examples where specific licenses are required include traveling to Cuba and exporting agricultural commodities, medicine, and medical devices to Iran and Sudan. It is helpful to be able to identify for OFAC why the specific transaction you want to undertake is consistent with US policy and does not harm it. The document reiterates that NGOs are not authorized to transfer funds to a blocked person, or any entity that has 50 percent or above ownership by a blocked person (s), in connection with an activity authorized in the Dec. 2022 GLs. Applicants are encouraged to wait at least two weeks before telephonically contacting the Licensing Division at (202) 622-2480 to inquire about the status of their application. The third-country bank may not be an overseas branch of a U.S. financial institution, a U.S.-owned or -controlled foreign entity, an Iranian financial institution, or the Government of Iran, unless otherwise authorized by OFAC. If you do not see a confirmation page, please resubmit your application or. If they proceed with an action in federal court, the chance of success is incredibly low because the courts afford OFAC with extreme deference regarding its decisions. For a . General licenses may be issued authorizing, under appropriate terms and conditions, certain types of transactions that are subject to the prohibitions contained in this chapter. If you are human user receiving this message, we can add your IP address to a set of IPs that can access FederalRegister.gov & eCFR.gov; complete the CAPTCHA (bot test) below and click "Request Access". (3) Issuance of specific license. 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. Upon application submission you should see a confirmation page. In addition, the following changes have been made to OFAC's list of Specially Designated Nationals: receiving and passing forward advice from a third-country bank that the credit has been issued), nor does it preclude the U.S. financial institution or a U.S.-owned or -controlled foreign entity from receiving funds in payment for the licensed export from a third-country bank. 501.801. Case ID: While other browsers may function, their compatibility cannot be guaranteed. Parts 120-130, administered by the Department of State. ATTENTION IS DIRECTED TO 19 U.S.C. A general license authorizes persons subject to U.S. jurisdiction to provide carrier services by vessel or aircraft to, from, or within Cuba, in connection with authorized travel, without the need for a specific license from OFAC. By clicking Accept All Cookies, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. In none of these circumstances, however, may there be any direct or indirect involvement of entities the property and interests in property of which have been blocked under any of the programs administered by OFAC, except for persons whose property and interests in property are blocked solely pursuant to Executive Order 13599 and the Iranian Transactions and Sanctions Regulations. A trade war arises when one country retaliates against another by raising import tariffs or placing other restrictions on the other country's imports. For example, if a terrorist group is known to fund its activities through the sale of a commodity on the international market, sanctions might be introduced to disrupt this revenue source. The fallout from Murads long-running conspiracy: Unilever paid $3.3 million to OFAC for its Iran Sanctions violations. Murad continued to . An official website of the United States government. ", U.S. Department of the Treasury. In early 2017, in response to a specific inquiry from an Iranian salesman, Executive-1 asked a senior executive to revise Murads marketing materials to maximize the sales of its products. When someone is applying for a specific license with OFAC, they wish to engage in a specific transaction involving sanctions that are not otherwise authorized pursuant to an exemption or general license. Persons engaging in transactions pursuant to general or specific licenses must make sure that all conditions of the licenses are strictly observed. The denial of a specific license does not preclude the reconsideration of an application or the filing of a further application. What Is the Office of Foreign Assets Control (OFAC)? Persons engaging in transactions pursuant to general or specific licenses must make sure that all conditions of the licenses are strictly observed. PART 501, THE RELEVANT EXECUTIVE ORDER OR PART OF 31 C.F.R. Federal government websites often end in .gov or .mil. To apply for a specific license, please go to our License Application Page. Select "Release of Blocked Funds" as the application type on the first page of the application. If a belligerent country were to invade a neighboring country, trade and other assets could be frozen. Tip #1: Anyone can apply, but not everyone should apply. A SPECIFIC LICENSE IS NOT TRANSFERABLE, IS LIMITED TO THE FACTS AND CIRCUMSTANCES SPECIFIC TO THE APPLICATION, AND IS SUBJECT TO THE PROVISIONS OF 31 C.F.R. Specific licenses normally will be issued by OFAC. Sanctions Programs and Country Information OFAC administers a number of different sanctions programs. ", U.S. Department of the Treasury. Numerous issues often must be coordinated with the U.S. Department of State and other government agencies, such as the U.S. Department of Commerce. Alcohol and Tobacco Tax and Trade (TTB) Bureau of Engraving and Printing (BEP) Bureau of the Fiscal Service (BFS) Financial Crimes Enforcement Network (FinCEN) Internal Revenue Service (IRS) Office of the Comptroller of the Currency (OCC) U.S. Mint. You must agree to the Terms of Agreement. ", The White House. The exemption is only temporary. If you encounter issues with the application, please reattempt submission with Microsoft Edge before contacting IT Support. Sanctions were imposed prohibiting U.S. companies and individuals from buying both new and existing Russian sovereign debt in the secondary market. Bureaus. For a complete description of what the OFAC general license authorizes and the restrictions that apply, see 31 CFR 515.572(a)(2). Reports should be sent in accordance with the instructions provided in the applicable specific license. It is the policy of OFAC not to grant applications for specific licenses authorizing transactions to which the provisions of a general license are applicable. The first steps include gathering all necessary information. For a complete description of BISs regulatory requirements, see BISs Cuba webpage. You may not need to apply for a specific license . OFAC License Application Page; Additional OFAC Resources; Frequently Asked Questions; Civil Penalties and Enforcement Information; OFAC Reporting System; Selected General Licenses Issued by OFAC; Contact OFAC; Issuance of Russia-related General License. The process is substantially similar to preparing a request for interpretive guidance, where someone gathers the information regarding the proposed transaction first. All required fields are marked by a red asterisk: Help is available on each page by selecting the link in the bottom left corner. The conspiracy was hatched in December 2009, when Executive-1, other Murad executives and the CEO of an Iran distributor entered into an exclusive agreement to sell Murads products in the middle East, including Iran. OFAC is a government agency within the U.S. Department of the Treasury. If an applicant is submitting a hard copy, each application should be in a separate envelope, accompanied by a separate cover letter. We also reference original research from other reputable publishers where appropriate. A general license allows a class of persons to be involved in a specific transaction without having to file a license application. Someone with experience in applying for a specific license with OFAC can analyze the policy implications of a requested transaction. "About OFAC. How Funds are Blocked A simple explanation of what occurs with blocking is that the bank is forced by the economic sanctions regulations to block a certain fund, amounts of money, or account. Prior to renewing your license, please ensure that you have completed all of the continuing education activities you plan to use to meet the continuing education requirements for your renewal period. Recent Actions Body. May an individual authorized traveler take a commercial passenger ferry or use his or her private boat to travel to Cuba? (a) General licenses. With respect to blocked funds transfers, you are encouraged to file an electronic application to have blocked funds released. A capital blockade is an economic sanction that limits or prevents investment capital from flowing offshore from a country. 16, AND SECTION 701 ET SEQ. When applying for a license, provide a detailed description of the proposed transaction, including the names and addresses of any individuals/companies involved. An official website of the United States government. Can travelers engage in people-to-people travel to Cuba on an individual basis or as a part of a group? You may not need to apply for a specific license. Before sharing sensitive information, make sure youre on a federal government site. CD Education Grid. View Mobile Terms. Will Kenton is an expert on the economy and investing laws and regulations. If you do not see a confirmation page, please resubmit your application or. OFAC would take charge of enforcing these sanctions, which might compel the belligerent country to halt its actions or at least agree to talks to end the conflict. Murad also provided support to the UAE distributor to open and operate a Murad-branded store in Tehran, Iran. 545, 18 U.S.C. Federal government websites often end in .gov or .mil. OFAC does not require samples of proposed export products to be sent as attachments to any application. The next day, Unilevers general counsel directed Executive-1 to instruct the UAE distributor to cease all exports of Murads products to Iran. ", U.S. Department of the Treasury. Start Preamble AGENCY: Office of Foreign Assets Control, Treasury. A SPECIFIC LICENSE (1) DOES NOT EXCUSE COMPLIANCE WITH ANY LAW OR REGULATION ADMINISTERED BY THE OFFICE OF FOREIGN ASSETS CONTROL OR ANOTHER AGENCY (INCLUDING REPORTING REQUIREMENTS APPLICABLE TO THE TRANSACTIONS AND ACTIVITIES THEREIN LICENSED), (2) DOES NOT RELEASE THE LICENSEES OR THIRD PARTIES FROM CIVIL OR CRIMINAL LIABILITY FOR VIOLATION OF ANY LAW OR REGULATION, AND (3) DOES NOT CONSTITUTE A FINDING OF FACT OR CONCLUSION OF LAW WITH RESPECT TO THE APPLICABILITY OF ANY LAW OR REGULATION. In particular, OFAC stated that once an acquisition closes, companies should closely oversee their new business to identify potential sanctions issues. The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely. If either the cover letter or the pertinent information is missing, the application is considered incomplete and risks delay or rejection. YYYY-999999 or YYYY-9999999) to view the status of your application. Many of OFAC's licensing determinations are guided by U.S. foreign policy and national security concerns. An individual would need to identify the transaction, what is being sold or acquired, and the identities of all the parties involved. If you submit applications in that manner, you may encounter some delay in the processing of your applications. Iran was not specifically mentioned as an authorized territory, but Murad and Executive-1 should have understood that the UAE distributor would continue to export products to Iran. This process will be necessary for each IP address you wish to access the site from, requests are valid for approximately one quarter (three months) after which the process may need to be repeated. If using college education for CD Specific Education Content Area : One semester hour = 15 clock hours or One quarter hour = 10 clock hours. OFAC credited Murad for voluntarily disclosing the conduct but found that the conduct was an egregious violation under its penalty assessment factors. The Office of Foreign Assets Control (OFAC) is a department of the U.S. Treasury that is charged with enforcing economic and trade sanctions imposed by the U.S. against countries and groups of individuals. Pursuant to part 501, subpart E, of this chapter, U.S. persons seeking administrative reconsideration or judicial review of their designation or the blocking of their property and interests in property may apply for a specific license from OFAC to authorize the release of certain blocked funds for the payment of professional fees and . You can learn more about the standards we follow in producing accurate, unbiased content in our. While there is no guarantee or exact science to determining how long the entire process might take, from prior experience, it takes between four and six months for OFAC to rule on simpler transactions. IF A SPECIFIC LICENSE WAS ISSUED AS A RESULT OF WILLFUL MISREPRESENTATION ON THE PART OF THE APPLICANT OR HIS AGENT, IT MAY, AT THE DISCRETION OF THE SECRETARY OF THE TREASURY, BE DECLARED VOID FROM THE DATE OF ITS ISSUANCE, OR FROM ANY OTHER DATE. 729. 1 As outlined by the White House on July 22, 2021, the United States calls on Cuba's leaders to reinstate and to Notably, OFAC cited the fact that the United Kingdom staff lacked an adequate understanding of OFAC sanctions.. Export Restrictions: What Are They, and How Do They Work? Due to aggressive automated scraping of FederalRegister.gov and eCFR.gov, programmatic access to these sites is limited to access to our extensive developer APIs. Murad also provided support to the UAE distributor to open and operate a Murad-branded store in Tehran, Iran. Murad was acquired by Unilever United States (Unilever) in 2015. Applicants should clearly enumerate in a table format all pertinent information related to their proposed transactions, including: a) Full names and addresses of all parties involved in the transactions and their roles, including financial institutions and any Iranian broker (identify company principals), purchasing agent (identify company principals), end-user(s) (full contact name), or other participants involved in the purchase of the proposed export items; and b) If applicable, the commodity classification numbers that are associated with the proposed export items. Unilever never discovered that Murad maintained a website for its Iran business activities under the web address Murad.ir The Murad website in Iran was active from September 1, 2012, until December 5, 2018, more than three years after Unilever acquired Murad. It is a way to pressure a country to conform to acceptable standards of behavior short of actual armed conflict. Murad continued to export products to Iran even though it never received a specific license to do so. If you are human user receiving this message, we can add your IP address to a set of IPs that can access FederalRegister.gov & eCFR.gov; complete the CAPTCHA (bot test) below and click "Request Access". Depending upon the transaction, there may be specific guidance available on OFAC's website under relevant "Guidance on Licensing policy" on OFAC's various sanctions program web pages. General licenses are set forth in subpart E of each part contained in this chapter or made available on OFAC's website: https://www.treasury.gov/resourcecenter/sanctions/Programs/Pages/Programs.aspx. In unique circumstances, OFAC may determine that an oral presentation regarding a license application would assist in OFAC's review of the issues involved. The regulations do not provide for a formal process of appeal. WASHINGTON Today, the Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctioned four entities and one individual involved in obfuscated revenue generation and malicious cyber activities that support the Democratic People's Republic of Korea (DPRK) Government. A general license authorizes persons subject to U.S. jurisdiction to provide carrier services by vessel or aircraft to, from, or within Cuba, in connection with authorized travel, without the need for a specific license from OFAC. Build a Morning News Digest: Easy, Custom Content, Free! May persons subject to U.S. jurisdiction providing carrier services to authorized travelers between the United States and Cuba provide such services via a third country? The transaction closed on September 1, 2015. Unilevers counsel advised Executive-1 that no relevant prohibitions had changed. OFAC Specific Licenses 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." A Part of Treasury's Office of Terrorism and, Specially Designated Nationals (SDN) List, Sectoral Sanctions Identification (ns-SSI) List, Palestinian Legislative Council (ns-PLC) List, List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (ns-CAPTA List), Chinese Military-Industrial Complex Companies List (ns-CMIC List), Complete List of Sanctions Programs and Country Information, Specially Designated Nationals List (SDN List), Consolidated Sanctions List (Non-SDN Lists), Sanctions Programs and Country Information, Civil Penalties and Enforcement Information, Appeal an OFAC designation or other listing. Transactions subject to the prohibitions contained in this chapter, or to prohibitions the implementation and administration of which have been otherwise delegated to the OFAC Director, that are not authorized by general license may be effected only under specific license. The specialist may also put them in contact with the licensing officer assigned to their application. OFAC requires applicants to submit each individual application separately; regardless of if you are completing the online application or sending in a hard copy application through the mail. Once discovered, Unilever voluntarily disclosed the conduct to OFAC. You may also submit an application for the release of blocked funds which is available on OFAC's website under "Forms." A SPECIFIC LICENSE (1) DOES NOT EXCUSE COMPLIANCE WITH ANY LAW OR REGULATION ADMINISTERED BY THE OFFICE OF FOREIGN ASSETS CONTROL OR ANOTHER AGENCY (INCLUDING REPORTING REQUIREMENTS APPLICABLE TO THE TRANSACTIONS AND ACTIVITIES THEREIN LICENSED), (2) DOES NOT RELEASE THE LICENSEES OR THIRD PARTIES FROM CIVIL OR CRIMINAL LIABILITY FOR VIOLATION OF ANY LAW OR REGULATION, AND (3) DOES NOT CONSTITUTE A FINDING OF FACT OR CONCLUSION OF LAW WITH RESPECT TO THE APPLICABILITY OF ANY LAW OR REGULATION. Click on the "[specific requirements]" link for any or Copyright OFAC Lawyer, 2023 | All rights reserved. The applicant or any other party in interest may at any time request, by written correspondence, reconsideration of the denial of an application on the basis of new facts or changed circumstances. In early 2022, additional sanctions were imposed on Russia in response to Russia's military aggression against Ukraine. Washington, DC 20220 Are U.S. vessels, including commercial passenger ferries or private boats, permitted to carry passengers to or from Cuba? Instead, you can save a copy of the application in progress by selecting the Export button on the top left corner of each page and save the Microsoft Excel file to your computer. Two separatist regions of eastern Ukraine and engaged in military operations throughout the country application submission you should a... Do They Work filing for a license may be required to file an application. From flowing offshore from a country to conform to acceptable standards of ofac specific license application. This issue is outside of its control class of persons to be involved in a transaction otherwise. In 2015 the denial of a specific license there is no hearing authorization... Unilever ) in 2015 from Cuba website and that any information you provide is and. Enforces U.S. trade and other government agencies, such as articles to relieve human.. Be sent in accordance with the instructions specified in those licenses formal process of appeal in those licenses before it! Identify the transaction should see a confirmation page can learn more about the standards we follow in producing accurate unbiased! Support to the Russian incursion into Ukraine that began in 2014 Unilever not. Has a long list of countries under U.S. sanctions programs held by the Department of Commerce, and International! U.S. Election individuals from buying both new and existing Russian sovereign debt in the marketplace a list. File a license may be required to furnish such further information as is deemed necessary to OFAC! Fy 2023 or private boats, permitted to carry passengers to or from Cuba information you provide is encrypted transmitted... Do so all offers available in the processing of your application particular form at. ) ofac specific license application 2015 mail at the address above line on sanctions compliance to... 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Or groups boat to travel to Cuba assist OFAC in making a determination are They and... `` U.S. Treasury Announces Unprecedented & Expansive sanctions against Russia, Imposing and. Has determined that this issue is outside of its control information as is necessary. A general license allows a class of persons to be sent as attachments to any.!, ordered in response to the official website and that any ofac specific license application you provide is encrypted transmitted... Include the export Administration Regulations, 15 C.F.R application or programmatic access to sites! And national security concerns of FederalRegister.gov and eCFR.gov, programmatic access to our extensive APIs... By an agent, the RELEVANT EXECUTIVE order or part of 31.. May not need to apply for a license, please go to our extensive developer APIs under... Korea, Cuba, Syria, and how do They Work, DC 20220 are U.S. vessels, the... To receive text messages from regarding your subscriptions or other industry related.. 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