Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced amendments to the general license (GL) that authorizes the export or re-export of certain medical devices to Iran. Prohibits imports or exports to or from the U.S.On December 22, 2016, the U.S. Importation of Goods Telecommunications Consumer Communications Devices Financial services Remittances Third-Country Effects Small Business Growth Cash in Advance Supporting Diplomatic Relations and Official USG Business Support for the Cuban People Gift Parcels Liberalizing License Application Review Policy January 15, 2015Ģ4 Cuba Changes Travel Travel and Carrier Services TelecommunicationsĬonsumer Communications Devices Third-Country Effects Cash in AdvanceĢ6 Crimea- E.O.
companies, including their foreign subsidiaries, from engaging in trade with Iran have been altered, other than in the statement of licensing policy relating to civil aviation safetyĢ3 Cuba Changes Travel Travel and Carrier Services Insurance Limited, temporary, and reversible sanctions relief in effect from January 20, 2014, to JCivil aviation safety statement of licensing policy None of the U.S. Important information to remember to include Applicant information Banks Brokers Purchasing agents End-users Shipment terms Payment mechanism Regulations allow for the export of food, medicine & medical devices to Iran Must fit the regulation’s definition Must not be destined for certain prohibited parties Anything outside these parameters must be authorized by a specific license. Gifts Patents, Trademarks & Copyrights Household goods Telecommunications and Mail Legal services Personal remittances Official business of certain International Organizations Sale of real property in Iran *Not a comprehensive list and adhering to certain conditionsġ9 Exports of Food, Medicine & Medical Devices
The licensing process Recent updates: Iran, Cuba, Crimea, and Ukraine General License Regulatory provision authorizing otherwise prohibited transactions No separate authorization necessary Issued into the regulations or on OFAC’s website Specific License Authorization from OFAC issued to a specific person(s) Allows a specific activity that would otherwise be prohibitedġ6 Agenda What is OFAC? Best practices for compliance Sudan, Cuba, Syria, Iran (ITSR and IFSR), Ukraine/Russia-related (Crimea) Limited Programs Burma (Myanmar), Conflict Diamonds, North Korea, Ukraine/Russia-related (Sectorial Sanctions) List-Based Programs (Activity): Counter-Terrorism, Non-Proliferation, Counter Narcotics Trafficking, Transnational Criminal Organizations, Somali Piracy, Grave Human Rights Abuses Via Information Technology, Foreign Sanctions Evaders (Regime): Balkans, Belarus, Burundi, Cote D’Ivoire, Democratic Republic of the Congo, Iraq, Lebanon, Libya, South Sudan-Related Sanctions, Ukraine/Russia-related, Venezuela-Related Sanctions, Yemen-Related Sanctions, Zimbabwe Risk Assessment Internal Controls Testing/Audit Responsible Individual(s) Trainingġ4 Sanctions Programs Comprehensive Programs OFAC’s prohibited parties list Currently, over 5,800 individuals and entities identified by OFAC Individuals, entities, vessels, banks all over the globe with whom or with which transactions are prohibited UPDATED FREQUENTLYħ Agenda What is OFAC? Best practices for compliance persons Transactions: Transactions by foreign persons to the extent that they involve the United States Transactions in property of a blocked person that comes within the United States In limited circumstances, transactions involving controlled U.S.-origin goods or technology.ĥ The Specially Designated Nationals (SDN) List persons Corporations, located anywhere in the world, doing business in the United States or through U.S. Department of the Treasury OFAC administers and enforces economic and trade sanctions against targeted: Foreign governments Individuals Entities PracticesĤ Jurisdiction Individuals, located anywhere in the world, doing business in the United States or through U.S. The licensing process Recent updates: Iran, Cuba, Crimea, and Ukraine Enforcement Guidelines Useful Resourcesģ What is OFAC? Office of Foreign Assets Control (OFAC) Massachusetts Export Center 2015 Export Expo DecemFrank Boudra Office of Foreign Assets ControlĢ Agenda What is OFAC? Best practices for compliance