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OFAC amended two long-standing sanctions programmes simultaneously:
IEEPA and the International Emergency Economic Powers Act; targets individuals/entities designated as Specially Designated Narcotics Traffickers (SDNTs).
under the Foreign Narcotics Kingpin Designation Act (21 U.S.C. § 1901 et seq.); targets "significant foreign narcotics traffickers" and associated entities placed on the Specially Designated Nationals (SDN) list under the Kingpin Act.
The four new or amended general licences introduced in parallel across both Parts:
1. Payment for legal services from non-US funds (new § 536.507 / § 598.508): Authorises US-person attorneys to receive professional fees and expense reimbursements from funds originating outside the United States, provided those funds do not originate from a US person or from any other blocked party (other than the SDNT client). Reporting and record-keeping requirements apply.
2. Payment for legal services from public funds (new § 536.508 / § 598.509): Authorises receipt of professional fees from US federal or state public funds (e.g., public defender compensation), removing the prior requirement for a specific licence in these cases.
3. Personal maintenance for incarcerated SDNTs (new § 536.509 / § 598.510): Authorises SDNTs in US federal custody or incarcerated in the United States to engage in limited personal maintenance transactions (basic living expenses while detained). Scope is restricted to the incarceration context.
4. Maintenance of blocked tangible property (new § 536.510 / § 598.511): Authorises SDNTs to make payments and receive goods/services for the upkeep of tangible property blocked under § 536.201 or § 598.202(a). Prevents blocked real estate and physical assets from deteriorating while legally frozen. A parallel provision (§ 536.206 / § 598.207) was added to the prohibitions subpart.
5. Emergency medical services — expanded (amended § 536.511 / new § 598.512): The existing NTSR GL for non-scheduled emergency medical services was expanded so that payment for such services (not just provision/receipt) is also covered. A new parallel GL was added to the FNKSR, which previously had no such provision.
A definitional edit added "wherever located" to the definition of "foreign person" at § 598.305, clarifying that dual nationals and foreign nationals regardless of geographic location fall within the FNKSR's scope.
criminal proceedings — particularly in complex cartel prosecutions where public defender offices or foreign-sourced retainers are common funding mechanisms.
managers, contractors) inadvertently servicing SDNT-owned real estate while it is frozen awaiting enforcement action.
due-process-oriented administrative liberalisation of two existing programmes.
Illicit Drug Trade Sanctions Regulations, enacted December 2021) once that newer programme matures operationally.