DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.
OFFICE OF FOREIGN ASSETS CONTROL
Executive Order of September 17, 2021
Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia
GENERAL LICENSE NO. 1
Official Activities of Certain International Organizations and Other International Entities
(a) Except as provided in paragraph (b) of this general license, all transactions and activities prohibited by Executive Order (E.O.) of September 17, 2021 that are for the conduct of the official business of the following entities by employees, grantees, or contractors thereof are authorized:
(1) The United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations;
(2) The International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA);
(3) The African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, and the Inter-American Development Bank Group (IDB Group), including any fund entity administered or established by any of the foregoing;
(4) The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and
(5) The African Union, including the African Union Commission and other subsidiary bodies and organs.
(b) This general license does not authorize any transactions or activities otherwise prohibited by E.O. of September 17, 2021, or prohibited by any part of 31 CFR chapter V, statute, or other E.O.
Bradley T. Smith
Acting Director
Office of Foreign Assets Control
Dated: September 17, 2021
[2-09-2022 Update. This GL has been implemented in the ESR at 550.510. Removed from OFAC's website]
1) This is a fairly standard "international organizations" GL, except that, unlike similar GLs it refers to "International Organizations and Other International Entities," as opposed to only the "United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations". Compare e.g., Venezuela General License 20; 510.514. Some of the non UN-Related organizations listed appear in other GLs, and some are specific to this GL.
2) By its terms, the GL is not limited to activities in which a U.S. person is a party to an underlying transaction. This means that U.S. persons may engage in ancillary transactions that would be subject to the otherwise-applicable prohibitions, even if such activities pertain to a transaction involving no U.S. person.
3) See General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof. Note that the addition of "Other Entities and Bodies" to the UN GLs , which began with Burma General License Number 2 (March 25, 2021), appears to constitute a substantive addition vis-a-vis previous, otherwise similarly-worded UN official business GLs.
4) See FAQ # 927, specifying that non-U.S. persons generally do not bear sanctions risk for engaging in activities that would be within the scope of this GL for a U.S. person.
5) "International Centre for Settlement of Investment Disputes (ICSID) and Multilateral Investment Guarantee Agency (MIGA) are not specialized agencies in accordance with Articles 57 and 63 of the Charter, but are part of the World Bank Group," which is a "specialized agency". See https://www.un.org/en/pdfs/un_system_chart.pdf (https://archive.md/wip/Uz33k).