Category Archives: Licenses

01.29.16
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Notice to Exporters 2016/06: License updates, including dual-use licenses

Following changes to the EU dual-use list, the following Open General Export Licences have been amended and republished:

Open general export licence (export for repair/replacement under warranty: dual-use items)

Open general export licence (export after repair/replacement under warranty: dual-use items)

Open general export licence (dual-use items: Hong Kong Special Administrative Region)

Open general export licence (technology for dual-use items)

Open general export licence (X)

Open general export licence (Turkey)

Open general export licence (export after exhibition: dual-use items)

For more details see Notice to Exporters: 2015/30.

Additionally, The Open General Trade Control Licence (Trade and Transportation: Small Arms and Light Weapons) has been updated to reflect the expansion of the list of items subject to Category B of the trade controls (trafficking and brokering):

Open general trade control licence (trade and transportation: small arms and light weapons)

The OGEL (Vintage Aircraft) has been updated to remove ML10b from the goods schedule, to update the text to refer to the Arts Council and to extend the time-period by which goods must be exported under this licence to six months (rather than three months) for consistency purposes.

Open general export licence (vintage aircraft)

Link:

Notice to Exporters 2016/06

 

12.09.15
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OFAC issues General License 1A for Banco Continental wind-down activities

Yesterday, OFAC issued a new General License for the anti-narcotics trafficking sanctions program, which authorizes transactions required to wind down the operations of Banco Continental SA, and liquidate it, after its seizure by Honduran authorities. It should be noted that the General License is only in effect until June 12, 2016.

Links:

OFAC Notice

General License 1A

 

12.08.15
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December 7, 2015: Complicated new 6-month Burma General License

Better just to quote the OFAC Notice…

Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a six-month general license to authorize certain trade-related transactions otherwise prohibited by the Burmese Sanctions Regulations (BSR). This general license allows individuals, companies, and financial institutions to conduct most transactions otherwise prohibited by the BSR that are ordinarily incident to the export of goods, technology, or non-financial services to or from Burma – including participating in trade finance transactions and paying port fees as well as shipping and handling charges associated with sending goods to or from Burma.

This general license authorizes certain transactions ordinarily incident to exports to or from Burma involving Specially Designated Nationals (SDNs) and SDN-owned entities involved in the exportation of goods to or from Burma; however, it does not authorize any transactions to, from, or on behalf of an SDN, or any other person whose property or interests in property are blocked, including any entity in which SDNs own, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest. This general license does not authorize a U.S. financial institution to advise or confirm any financing by SDNs or blocked persons. It also does not impact other prohibitions in the BSR; the ban on new investment involving the Ministry of Defense, state or non-state armed groups, any entity in which any of the foregoing own a 50 percent or greater interest, and SDNs or other blocked persons remains fully in effect, as does the prohibition on the import into the United States of Burmese-origin jadeite, rubies, and jewelry containing them.

In addition to authorizing certain transactions until June 7, 2016, this general license also authorizes U.S. financial institutions to unblock and return transactions blocked on or after April 1, 2015 that would have qualified as authorized had they been engaged in pursuant to the authorization in the general license.

This general license is intended to support U.S. and Burmese exporters and to facilitate trade with Burma. More specifically, this general license is an effort to calibrate the impact of our Burma sanctions and to support the ongoing flow of trade with Burma. Supporting Burma’s economic development – including the encouragement of normal trade with non-sanctioned businesses in Burma – is a key foreign policy goal. Today’s general license supports the prior easing of U.S. economic sanctions on Burma in response to significant positive reforms in the country, while maintaining targeted sanctions against specific individuals and entities.

Links:

OFAC Notice

Temporary General License

 

11.17.15
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November 2, 2015: OFAC adds to medical supplies licensable for Iran export

Update to the Iranian Transactions and Sanctions Regulations, 31 CFR Part 560, Section 560.530(a)(3)(i), Adding Additional Items to the List of Medical Supplies General License
11/2/2015
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The Department of the Treasury's Office of Foreign Assets Control (OFAC) is updating the List of Medical Supplies eligible for exportation or reexportation to Iran under the general license set forth at section 560.530(a)(3)(i) of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), to include additional items that meet the definition of the term “medical supplies” set forth at section 560.530(a)(3)(ii) of the ITSR and referenced in the general license originally issued on October 22, 2012 for the export of basic medical supplies to Iran.
For reference, OFAC previously published related frequently asked questions on the general license to provide guidance on the scope and limitations of this general license. OFAC also previously released guidance on the sale of food, agricultural commodities, medicine, and medical devices by non-U.S. persons to Iran.

Links:

OFAC Notice

List of Medical Supplies

 

11.12.15
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November 11, 2015: HMT Iran guidance document updated

Yesterday, Her Majesty's Treasury (HMT) updated the guidance document “Guidance on whether or not a transfer of funds requires Prior Notification or Prior Authorisation” on the Iran licensing policy page on uk.gov. Unfortunately, there are no notes in the email notification or in the document explaining what has changed.

Link:

HMT Guidance document

 

11.05.15
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October 29, 2015: Temporary General License issued for OFAC Belarus sanctions

Unlike most General Licenses, this one is only in effect until April 30, 2016, unless otherwise extended. It authorizes all transactions with the following firms that were sanctioned under Executive Order 13405:

    • Belarusian Oil Trade House
    • Belneftekhim
    • Belneftekhim USA, Inc.
    • Belshina OAO
    • Grodno Azot OAO
    • Grodno Khimvolokno OAO
    • Lakokraska OAO
    • Naftan OAO
    • Polotsk Steklovolokno OAO

It is subject to the usual “don't involved other SDNs” restriction, and doesn't apply to property which is already blocked. However, in addition, if your transactions exceed $10,000, you have to file a report with the State Department (by mail or by emailing BelarusGL@state.gov), containing the following information:

(1) Estimated or actual dollar value of the transaction(s), as determined by the value of
the goods, services, or contract;

(2) The parties involved;


(3) The type and scope of activities conducted; and

(4) The dates or duration of the activities.

Links:

OFAC Notice

Belarus General License