On December 7, 2010, the Office of Foreign Assets Control of the U.S. Department of the Treasury (“OFAC”) amended the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (the “GTSR”), and the Terrorism Sanctions Regulations, 31 C.F.R. part 595 (the “TSR”), to expand the scope of authorizations in each of those programs for the provision of certain legal services. OFAC also added new general licenses to the GTSR, the TSR, and the Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597, to authorize payments from funds originating outside the United States for certain legal services to or on behalf of blocked persons, as well as the formation of legal defense funds to gather donations and dispense funds in connection with payments for such legal services. The final rule containing these amendments was published at 75 FR 75904 (December 7, 2010).
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