On August 25, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a License (the License) pursuant to OFAC’s Global Terrorism Sanctions Regulations (GTSR or SDGT Sanctions) and Foreign Terrorism Organizations Sanctions Regulations (FTOSR) following a request from the Department of State.  Under Section 1 of the License, the U.S. Government, its employees, grantees, contractors, and others acting on the U.S. Government’s behalf (collectively the Licensees) are authorized to “engage in all transactions necessary and ordinarily incident to the provision of humanitarian assistance in Afghanistan,” which would otherwise be prohibited under GTSR or FTOSR.  As such, the identified licensees may engage in humanitarian-related transactions involving the Taliban, provided such transactions are not otherwise prohibited by any other sanctions law or regulation.  Further, the License permits the transfer of funds for authorized transactions through the U.S. financial system, and does not require blocking or rejecting such transactions.  The License contains other customary restrictions, cautions, and record-keeping requirements required by OFAC. For example, if a Licensee is making use of the License to cover activities of persons acting on the U.S. Government’s behalf, that person must receive a copy of the License.

The license is set to expire on March 1, 2022, though it may be revoked or modified at any time prior to its expiration. The Department of State may request additional licenses as well by submitting a request to the Department of the Treasury no later than 30 days prior to the desired effective start date.

For more information regarding the License and sanctions-implications in Afghanistan, contact our team and see previous posts below.

OFAC Revokes Belarus General License (General License 2G or GL 2G) | International Trade Law (cmtradelaw.com)

OFAC Sanctions Network Attempting to Evade U.S. Sanctions on Venezuela’s Oil Sector | International Trade Law (cmtradelaw.com)

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

Photo of Martín Yerovi Martín Yerovi

Martín Yerovi is an international trade analyst in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection…

Martín Yerovi is an international trade analyst in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. He also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).