CSS CSS Licensing & Exemptions

Question 1

What is a 'specific license' in the OFAC licensing framework?

Accepted Answer

An individual authorization granted by OFAC for a particular transaction or set of transactions

Answer

A blanket authorization covering a broad category of transactions

Answer

A license issued by FinCEN for money transmission

Answer

A State Department export license for dual-use goods

Question 2

A 'general license' under OFAC's framework authorizes:

Accepted Answer

A class of transactions for all qualifying persons without requiring individual OFAC approval

Answer

Only U.S. government agencies to transact with sanctioned parties

Answer

Financial institutions to conduct due diligence on sanctioned parties

Answer

Transactions below a specified dollar threshold

Question 3

Which OFAC general license typically permits transactions related to personal remittances to certain sanctioned countries?

Accepted Answer

Personal remittance general licenses specific to each country program

Answer

General License 1 (Emergency transactions)

Answer

FinCEN Remittance Corridor Rule exemption

Answer

State Department humanitarian general license

Question 4

When applying for a specific OFAC license, applicants must typically demonstrate which of the following?

Accepted Answer

That there is a licensing policy favoring the activity and the transaction serves a legitimate purpose

Answer

That the transaction is commercially profitable

Answer

That competing U.S. companies do not offer the same goods or services

Answer

That the sanctioned party has filed for removal from the SDN List

Question 5

What is the 'informational materials' exemption under OFAC sanctions?

Accepted Answer

A statutory exemption that permits importing and exporting informational materials regardless of sanctions

Answer

An exemption for academic textbooks sold in sanctioned countries

Answer

An exemption for U.S. government propaganda

Answer

A license for exporting software to sanctioned parties

Question 6

OFAC's 'emergency exception' typically permits which type of transaction without a license?

Accepted Answer

Transactions necessary to protect human life in an imminent emergency

Answer

Any transaction exceeding $1 million in humanitarian value

Answer

Transactions authorized by the UN Security Council

Answer

Any transaction approved by the U.S. Secretary of State