31 CFR § 501.801 Licensing.

Date issued: Jun. 21 2019

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TURBOFAC Commentary (707 words)

Notes:

1) JUNE, 2019 AMENDMENTS

This provision was amended substantially in June, 2019. The following are the notable changes.

*The NGO Registration procedures have been removed. With the removal of the SSR, NGOs no longer need to formally register with OFAC in order to qualify for any NGO-specific general licensees.

*Another notable change is the addition note that "[l]icense applications submitted to OFAC and specific licenses issued by OFAC are subject to the FOIA and generally will be released upon the receipt of a valid FOIA request." In practice, OFAC interprets the FOIA exemptions quite broadly, such that the applicants are contacted prior to any release of information, even where the applicants have not specifically requested confidential treatment or otherwise indicated that the application submitted contains information qualifying for one or more FOIA exemptions....