CSS CSS Licensing & Exemptions 2

Question 1

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

Accepted Answer

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

Answer

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.

Question 2

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

Accepted Answer

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

Answer

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.

Question 3

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

Accepted Answer

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

Answer

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.

Question 4

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

Accepted Answer

Administrative Reconsideration or Delisting Request

Answer

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.

Question 5

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

Accepted Answer

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

Answer

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.

(CSS) Certified Sanctions Specialist Practice Test

(CSS) Certified Sanctions Specialist Practice Test

CSS CSS Licensing & Exemptions 2