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CSS Licensing & Exemptions Flashcards

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  1. Under which OFAC policy is food, medicine, and medical devices generally authorized for export to comprehensively sanctioned countries?

    Answer: Trade Sanctions Reform and Export Enhancement Act (TSRA) of 2000

    TSRA established a licensing framework allowing the export of food, medicine, and medical devices to Cuba, Iran, Sudan, and Libya, subject to conditions including payment and licensing requirements.

  2. A U.S. attorney representing a sanctioned client in ongoing litigation is typically authorized under which OFAC framework?

    Answer: A general license authorizing legal services related to a blocked person's defense in legal proceedings

    Most OFAC sanctions programs include a general license permitting U.S. persons to provide legal services to sanctioned parties in connection with ongoing legal proceedings, though receipt of fees may still require a specific license.

  3. What is the purpose of OFAC's 'wind-down' general license when a new sanctions designation is issued?

    Answer: To provide a limited time period for parties to conclude pre-existing contracts with a newly designated entity

    Wind-down licenses give U.S. persons a limited time (often 30–90 days) to conclude pre-existing contracts or commitments entered before a new designation, reducing disruption to innocent parties.

  4. Which OFAC process allows a designated party to formally request removal from the SDN List?

    Answer: Administrative Reconsideration or Delisting Request

    Designated parties may submit an administrative reconsideration request or delisting petition to OFAC presenting evidence that the designation was incorrect or circumstances have materially changed.

  5. A humanitarian organization seeking to deliver food aid to a comprehensively sanctioned country should primarily rely on:

    Answer: OFAC humanitarian general licenses and/or a specific license for activities not covered by general licenses

    Humanitarian organizations should first analyze applicable OFAC general licenses, and for activities not covered, apply for a specific license — OFAC has a dedicated licensing policy for bona fide humanitarian work.

  6. What is an OFAC 'No Action' letter?

    Answer: An informal communication where OFAC indicates it does not intend to take action on a described transaction or activity

    An OFAC No Action letter is an informal guidance communication (not a binding ruling) indicating OFAC does not plan to take action against a specific described activity, often used for novel or edge-case fact patterns.