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A General License by any other name…

So, today’s designations to the SDN and NS-MBS Lists, General License, and FAQs are all related to PEESA – the Protecting Europe’s Energy Security Act. The General License is called PEESA General License 1, but there is no PEESA sanctions program (and OFAC web page).

It appears under the Ukraine/Russia-related sanctions page, and is named that way to differentiate it from all the other General Licenses, which all have “Ukraine” in the title.

A lot of the other General Licenses – but not all – follow a naming convention which includes the name of the program. A few of the Iran GLs do not have “Iran” in the name, for example. But, perhaps more cogently, why break out the PEESA General License? There are tons of different Iran-related authorities, but all those GLs just say “Iran”.

Maybe all the Russia-related sanctions should be lumped together in one place? Or maybe at least we should have a clear naming convention, that also carries through to the titling in the actual document. Ukraine GL 7 just refers to Executive Order 13685, for example.

Maybe one day OFAC will do some spring cleanup…

Categories: Licenses


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