No. OFAC’s action of December 20, 2022 does not restrict the scope of any existing exemptions or OFAC authorizations for humanitarian activities, including existing general licenses authorizing certain NGO activities in sanctioned jurisdictions such as the Crimea Region of Ukraine, Iran, and Syria… Read more
No, provided the petroleum products are unloaded at the port of destination prior to 12:01 a.m., eastern daylight time, April 1, 2023. Petroleum products of Russian Federation origin that are loaded onto a vessel at the port of loading prior to 12:01 a.m., eastern standard time, February 5, 2023,… Read more
On May 17, 2024, OFAC amended 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) to incorporate the provisions of General License (GL) D-2 into 31 CFR § 560.540, with certain additional amendments. Section 560.540 supersedes GL D-2, which OFAC issued on September 23, 2022… Read more
On January 26, 2023, OFAC designated Frigorifico Chajha S.A.E. (Frigorifico Chajha), pursuant to E.O. 13818 . Concurrent with this action, OFAC issued General License (GL) 5 , which authorizes certain transactions ordinarily incident and necessary to the divestment or transfer, or the facilitation… Read more
No. U.S. persons, including U.S. financial institutions, may transfer securities issued by non-blocked Russian entities from a decedent’s estate to the account of a relevant beneficiary or beneficiaries, including a successor entity (e.g., a family trust), provided such transfers (i) are part of… Read more
On February 24, 2023, the Director of OFAC, in consultation with the Department of State, issued a sectoral determination pursuant to Executive Order (E.O.) 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and mining… Read more
For the purposes of the determination of February 24, 2023 made pursuant to E.O. 14024 , OFAC anticipates publishing regulations defining 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… Read more
No. The Director of OFAC, in consultation with the State Department, has issued a determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. A… Read more
Persons providing web hosting services authorized pursuant to 31 CFR § 515.578 may reasonably rely on information provided to them by their customers in the ordinary course of business, unless they know or have reason to know their provision of web hosting services is for the promotion of tourism… Read more
Yes. Section 515.578(a)(1)(i) of the CACR authorizes the direct or indirect exportation or reexportation to Cuba, from the United States or by a person subject to U.S. jurisdiction, of certain services. Among these are API-related services incident to the exchange of communications over the… Read more