A Little Bit of Guidance on OFAC General License G, Clean Up Duty: OFAC Acknowledges an Unblocking Under the 50 Percent Rule and Re-issues Venezuela-related General Licenses, OFAC Continues Iran Designations Despite COVID-19 Outbreak. In separate, but related, December actions, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published new sanctions lists largely aimed at companies tied to the Chinese military. U.S. Implementation in the Export Administration Regulations of the United States’ Rescission of Sudan’s Designation as a State Sponsor of Terrorism. The Department of Commerce's Bureau of Industry and Security (BIS) announced the impending addition of the People’s Republic of China’s Ministry of Public Security’s Institute of Forensic Science and eight Chinese companies to the Entity List, which will result in these parties facing new restrictions on access to U.S. technology. Prior to March 14, 2019, this entity was on OFAC’s Part 561 List. The Fine Print: Export Privileges are denied by written order of the Department of Commerce. The BIS Denied Persons List differs even from the Entity List because it can target both U.S. and foreign persons, and imposes strict licensing requirements which typically come with a presumption of denial. OFAC-CSL: Consolidated Sanctions List (Department of the Treasury – Office of Foreign Assets Controls (OFAC)) including: ... Bureau of Industry and Security (BIS)) LADP: List of Administratively Debarred Parties (Department of State – Directorate of Defence Trade Controls (DDTC)) List of Restricted Entities and Subentities Associated With Cuba Effective January 8, 2021 Frequently Asked Questions on the Cuba Restricted List White House The Office of Foreign Assets Control (OFAC) is a department of the U.S. Treasury that administers and enforces economic and trade sanctions. In other words, a license from BIS would be required to ship most items to Syria and other OFAC sanctioned countries, or could be prohibited. The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. On October 14, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) announced further amendments to ease U.S. sanctions and export control restrictions applicable to Cuba. Despite their differences, these lists have one thing in common: an administrative reconsideration process. Any questions regarding the OFAC Russian sanctions program should be directed to OFAC. 7 to part 744 of the EAR) identifies foreign parties that are prohibited from receiving items described in Supplement No. OFAC-API.com imports, sorts and formats the OFAC SDN list each hour, allowing for optimized search times and up to date result sets. @JanetYellen and I know that this is not a moment, it’s a movement – so we’re turning climate energy into climate action…, RT @ABC: "This is really an urgent need, and we need to act big, we have to make sure that we provide a bridge so that people aren’t scarre…, Form 941, employer's quarterly federal tax return, Civil Penalties and Enforcement Information, ​​S​ectoral Sanctions Identifications ListÂ, Non-SDN Palestinian Legislative Council List, T​​he List of Foreign Financial Institutions Subject to Part 561 (the "Part 561 List"), List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), Non-SDN Menu-Based Sanctions List (NS-MBS List), Information about OFAC's File Transfer Protocol (FTP) Server, If you have an OFAC Alert on your Credit Report, Click here to appeal an OFAC designation or other listing​, Special Inspector General, Troubled Asset Relief Program (SIGTARP), Special Inspector General for Pandemic Recovery (SIGPR), Administrative Resource Center (ARC)- Bureau of the Fiscal Service. The Entity List consists of foreign end users who pose an unacceptable risk of diverting U.S. exports and the technology they contain to alternate destinations for the development of weapons of mass destruction. As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. The Military End User List (Supplement No. List of active sanction programs under OFAC apply to the following countries and activities: Conflict Diamonds. A list of the Recent Changes to the DPL that have occurred within the last 90 days and. • BIS and Treasury’s Office of Foreign Assets Control (OFAC) share jurisdiction: – BIS licenses exports & reexports of items subject to the EAR – Treasury (OFAC) licenses travel, financial activities, services for U.S. persons – Consult with OFAC for guidance On the other hand, the two BIS Lists are quite different. For example, the BIS Entity List imposes upon foreign persons license requirements supplemental to those found elsewhere in the Export Administration Regulations (EAR). Any transaction to which a listed person is a party will be deemed by BIS to raise a Red Flag. U.S. REGULATORY OVERSIGHT OVER TRADE AND TRAVEL WITH CUBA BY THE DEPARTMENT OF TREASURY OFFICE OF FOREIGN ASSET CONTROL (OFAC) AND DEPARTMENT OF COMMERCE , BUREAU OF INVESTATIVE SERVICES (BIS) Trade and travel with or involving Cuba, by individuals, or transactions with a U.S. “Exus”, are regulated by many U.S. Laws. BIS implements U.S. government sanctions against Cuba, Iran, North Korea, Sudan, and Syria pursuant to the EAR, either unilaterally or to implement UN Security Council Resolutions. Consolidated Sanctions List Data Files Last Updated: 12/14/2020 In order to make it easier to comply with OFAC's sanctions regulations, the office is now offering all of its non-SDN sanctions lists in a consolidated set of data files "the Consolidated Sanctions List". OFAC acts under Presidential wartime and national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze foreign assets under U.S. jurisdiction.. Please visit the links below for more information about each list. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com. While a BIS list, the naming of parties to the Entity List, the modification of their entries, and their removal is the responsibility of the End-User Removal Committee (ERC), an inter-agency group with representatives from various U.S. departments, including Commerce, Defense, and Energy. Cyber-related Crimes. DOC Releases BIS Annual Report to Congress for Fiscal Year 2020. These consolidated files comply with all OFAC's existing data standards. For additional information BIS provides the following links: Executive Orders related to Russian sanctions OFAC & BIS. Specially Designated Nationals Lists - OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. Human Rights Abuse (Magnitsky Act) Narcotics Trafficking. BIS DPL The Bureau of Industry and Security (BIS) - Commerce Department publishes the Denied Persons List (DPL) containing individuals and companies who have been denied export and re-export privileges by BIS. According to OFAC, Amazon violated U.S. regulations by conducting retail e-commerce transactions with persons in sanctioned territories, persons on OFAC’s List of Specially Designated Nationals (SDNs), and sanctioned country embassies around the world. The OFAC SDN List is a list of over 6,000 persons and entities that have been blocked pursuant to any number of U.S. economic sanctions programs. Search OFAC's Sanctions Lists Including the SDN List Search OFAC's Sanctions Lists Information About OFAC's Sanctions List Search Tools Unverified List - End-users who BIS has been unable to verify in prior transactions. The OFAC SDN List is a list of over 6,000 persons and entities that have been blocked pursuant to any number of U.S. economic sanctions programs. On July 9, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced in a press release its decision to add the Xinjiang Public Security Bureau (XPSB) and four Chinese government officials to the list of Specially Designated Nationals and Blocked Persons (SDN List). OFAC Targeted Countries and Activities.  Please visit the links below for more information about each list. Â, Information About OFAC's Sanctions List Search Tools​​, Budget, Financial Reporting, Planning and Performance, Financial Markets, Financial Institutions, and Fiscal Service, Treasury Coupon-Issue and Corporate Bond Yield Curve, Treasury International Capital (TIC) System, Kline-Miller Multiemployer Pension Reform Act of 2014, FACT SHEET: Treasury to Work to Ensure Families Get Access to Economic Impact Payments, Explore the History of the U.S Department of the Treasury, Tax Filing Season Begins February 12; Learn More Tax Tips and Ways to Speed Your Refund, Treasury Announces Appointment of Several Members of Staff, Report to the Secretary of the Treasury from the Treasury Borrowing Advisory Committee of the Securities Industry and Financial Markets Association, Minutes of the Meeting of the Treasury Borrowing Advisory Committee of the Securities Industry and Financial Markets Association February 2, 2021, Statement from Secretary of the Treasury Janet L. Yellen on the Congressional Budget Office Economic Outlook Report, Statement by Secretary Steven T. Mnuchin on Passage of the Coronavirus Response and Relief Supplemental Appropriations Act, Remarks by Counselor to the Secretary Carter Burwell at the Washington Institute, RT @ClimateEnvoy: . The Denied Persons List consists of individuals and companies that have been denied export and re-export privileges by BIS. This list is updated frequently and also includes individuals, entities, vessels, and banks all over the world owned, controlled by, or acting on behalf of targeted governments or groups. The sanctions can be either comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals. Foreign Election Interference. Similarly to OFAC, BIS keeps a list of regulated items called the Commercial Control List (CCL). Where is OFAC's country list? The license requirements, license exceptions, and licensing policy vary … Parties are added to this list by issuance of a Temporary or Permanent Denial Order, and the export, reexport, or transfer of an item to a party on this list constitutes a violation of the EAR. BIS has broad jurisdiction over U.S. origin items. The OFAC SDN List is a list of over 6,000 persons and entities that have been blocked pursuant to any number of U.S. economic sanctions programs. As the Founder and Principal of Ferrari & Associates, P.C., Mr. Ferrari represents U.S. and foreign corporations, financial institutions, exporters, insurers, as well as private individuals in trade compliance, regulatory licensing matters, and federal investigations and prosecutions. While most sanctions are administered by OFAC, BIS has jurisdiction over certain export prohibitions (via “embargo” regulations), as it is the case with exports to Syria6 . Alcohol and Tobacco Tax and Trade Bureau (TTB), Financial Crimes Enforcement Network (FinCEN), Office of the Comptroller of the Currency (OCC), Treasury Inspector General for Tax Administration (TIGTA), Special Inspector General for the Troubled Asset Relief Program (SIGTARP), Budget Request/Annual Performance Plan and Reports, Inspector General Audits and Investigative Reports, Treaties and Tax Information Exchange Agreements (TIEAs), Foreign Account Tax Compliance Act (FATCA), The Community Development Financial Institution (CDFI) Fund, Specially Designated Nationals List (SDN List), Sanctions Programs and Country Information, Financial Literacy and Education Commission, The Committee on Foreign Investment in the United States (CFIUS), Macroeconomic and Foreign Exchange Policies of Major Trading Partners, U.S.-China Comprehensive Strategic Economic Dialogue (CED), Small and Disadvantaged Business Utilization, Debt Management Overview and Quarterly Refunding Process, U.S International Portfolio Investment Statistics, Report Fraud Related to Government Contracts, Cashing Savings Bonds in Disaster-Declared Areas, Community Development Financial Institution (CDFI) Fund, Electronic Federal Benefit Payments - GoDirect, General Property, Vehicles, Vessels & Aircraft, In addition to its list of Specially Designated Nationals and Blocked Persons, OFAC maintains other sanctions lists. Below is a list of links to the Office of Foreign Assets Control's Specially Designated Nationals and Blocked Persons list, the Bureau of Industry and Security's Denied Parties List, the Entry List and the Office of Defense Trade Controls' Debarred Persons Lists.Each agency is responsible for maintaining and updating their respective lists. BIS Imposes Administrative Penalties for Submission of False or Misleading Export Information Involving Russia. A lot of time folks dealing with import-export compliance issues get confused by the lists; namely, the List of Specially Designated Nationals and Blocked Persons (SDN List) administered by the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Proscribed Persons Lists administered by the Bureau of Industry and Security at the U.S. Department of Commerce which is comprised of the Entity List and the Denied Person’s List. While those processes differ, there at least is a way to be removed from these lists if one was so inclined and willing to undergo the process. The Denied Persons List consists of individuals and companies that have been denied export and re-export privileges by BIS. OFAC administers a number of different sanctions programs. What this means is that the assets of any person, be it an individual or an entity, appearing on this list which is subject to U.S. jurisdiction is to immediately be blocked and U.S. persons are prohibited in engaging in almost all types of transactions with them. BIS places entities on the Entity List based on certain sections of part 744 (Control Policy: End-User and End-Use Based) and part 746 (Embargoes and Other Special Controls) of the EAR. The impact of being on the Entity List can be devastating. United States Department of the Treasury’s Office of Foreign Assets Control. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. He frequently represents clients before the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United States Department of Commerce’s Bureau of Industry and Security (BIS), and in federal courts around the country. Conviasa: Is OFAC Closing the Cabin Door? In a similar vein, BIS is taking action “to ensure the efficacy of existing sanctions on the Russian Federation (Russia) for violating international law and fueling the conflict in eastern Ukraine.” OFAC announced the following additions to the SDN List: The Only Comprehensive Resource on U.S. Economic Sanctions. The export, reexport, or transfer of an item to a party on this list without a license required by the Entity List is a violation of the EAR. Information on "Standard" denials. Despite BIS’s important role, many compliance professionals are not even aware of what the EAR stands for, let alone what it prohibits. The presence of a party on this list in a transaction is a “Red Flag” that should be resolved before proceeding with the transaction. The Bureau of Industry and Security ("BIS") of the U.S. Department of Commerce maintains separate lists for the purposes of the programs that it administers (including the Denied Persons List and the Entity List). The changes went into effect on October 17, 2016. For enforcement, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope, and involve close cooperation with allied governments. The following should offer some insight into the differences between these lists and why you need to know about all of them if you are planning to import or export internationally. BIS advises exporters, reexporters, transferors, and those providing certain services in Russia to review the OFAC requirements in this area. In addition to its list of Specially Designated Nationals and Blocked Persons, OFAC maintains other sanctions lists. Each order affecting export privileges is published in the Federal Register. 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