31 CFR § 501.801 Licensing (With Version Proposed in 5-8-24 Interim Final Rule)

Date issued: May. 08 2024

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TURBOFAC Commentary (887 words)

Update – on 5-8-24, OFAC published an “Interim final rule” announcing amendments to this RPPR provision and others, to be effective 90 days after its 5-10-24 publication in the FR. The left side of the screen includes the revised provision and the pre-existing provision. See the back of the PDF file for the Interim final rule and a redline comparing the revised and pre-existing versions.

The differences between the revised and pre-existing versions are limited to technical changes; adding requirements mandating the use of the “ORS” for submitting reports; specifying that applications can be made for the issuance, amendment, or repeal of a general license, and specifying that records will not be released via FOIA where “OFAC reasonably foresees that disclosure would harm an interest protected by a FOIA”. This revision is less FOIA-friendly than the prior version, but it accords with...