At the suggestion of Mr. Nicholas Turner from Steptoe & Johnson HK LLP, who was a Speaker at the 36th ABA General Meeting and Conference held in November 2019 in Makati, Philippines, we would like to share with our members an interactive chart summarizing OFAC (Office of Foreign Assets Control) licenses that permit banks to process certain payments related to COVID-19 and humanitarian relief efforts in Crimea, Cuba, Iran, North Korea, Syria, and Venezuela.
As ABA members may be aware, exporters, non-governmental organizations, financial institutions, and individuals that are subject to US jurisdiction may require a license from the US Treasury Department’s Office of Foreign Assets Control (OFAC) to support COVID-19 relief efforts in territories subject to comprehensive US sanctions (e.g., Crimea, Cuba, Iran, North Korea, Syria) and territories whose governments are subject to stringent US sanctions (e.g., Venezuela). Their shipments may also be subject to the Export Administration Regulations (EAR). The chart provides a brief summary of humanitarian general licenses (GLs) and license exceptions that may apply to COVID-19 relief efforts and other humanitarian activities.
Steptoe (www.steptoe.com) has international reputation for vigorous representation of clients before governmental agencies, successful advocacy in litigation and arbitration, and creative and practical advice in structuring business transactions. The firm is particularly noted for its capabilities in: (a) white-collar defense and other government investigations and enforcement; (b) high-stakes litigation; (c) patent and technology litigation; (d) preventive international corporate compliance; and € challenging regulatory issues before the US government.