OFAC General License v. Specific License?

What is the difference between a general license and a specific license, for purposes of OFAC sanctions programs? OFAC sanctions programs prohibit certain transactions and activities with countries, entities or individuals, but OFAC will often issue general licenses which are exceptions to the prohibitions, which apply to everyone, or certain classes of individuals. It is a blanket authorization, as long as you strictly follow its terms and conditions. These general licenses are published on their web site and will be numbered in order, such as GL1, GL2, etc. A general license may have a certain validity period, for example, a general license to wind down activities so businesses have a time period in which to stop doing business with a sanctioned party. Other examples are, there may be general licenses for humanitarian aid or personal expenses.

A specific license is where there is no general license covering the activity or transaction, and a person or entity applies to OFAC for a license. Certain types of applications for specific licenses may have a presumption of denial, so it may not be worthwhile.? However, OFAC may approve other types of requests for specific licenses. An application for a specific license will require extensive documentation and the application may be pending for a few months up to a couple of years before OFAC replies. You and your company must wait for a specific license to be approved before engaging in the prohibited transaction. A specific license is not transferable, and is limited to the facts and circumstances particular to the application. Individuals who are the victims of mistaken identity and are not the same person as an SDN may also apply for a specific license. #OFAC #generallicense #specificlicense #sanctions #SDN #mistakenidentity

This article is for general informational purposes only and is not intended as legal advice. Copyright 2024 ? Heidi J Meyers, all rights reserved.