CSS Licensing & Exemptions Flashcards
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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.
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.
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.
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.
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.
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.