Holy ship!

While most of OFAC’s sanctions programs are targeted to lists of specific individuals and companies, there are still a number of programs that are far-reaching, covering entire governments and/or countries. These programs, in general, embargo every transfer of assets involving nationals of the affected country or all institutions and persons affiliated with the government.

However, when it serves the interests of the sanctions program, exceptions are granted. OFAC issues both General Licenses, which cover a general type of transaction, and Specific Licenses, which authorize a specific business deal.

Examples of General Licenses include:

  • US citizens can send limited amounts of money to their Cuban relatives each year
  • Social media freeware can be provided to citizens of certain sanctioned countries in order to promote information exchange and greater freedom
  • Legal fees can be paid to lawyers for the purpose of fighting a designation on the SDN list
  • Humanitarian aid, cultural and educational exchanges are permitted to otherwise-embargoed countries

On Thursday, OFAC issued a very limited General License. An Iranian cargo vessel that appears on the SDN list, the MV Dianthe (fka Iran Bam and Horsham), was seized by Indian authorities. OFAC is now permitting financial transactions to the seizure and sale of that vessel.

Link:

General License 5b of the Weapons of Mass Destruction Proliferators Sanctions Regulations

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