Industrial Policy & Trade Monitor· 2674 actions· ✨ 91 recent

The Office of Foreign Assets Control (OFAC) issued a final rule on 19 December 2024 amending 32 parts of 31 CFR chapter V to modernize the general licenses authorizing payments for legal services from funds originating outside the United States. The rule replaces the annual reporting requirement that had applied to such payments with a 10-year recordkeeping requirement, aligning the legal-services general licenses with the new 10-year statute of limitations for IEEPA/TWEA violations and OFAC's parallel 5→10-year recordkeeping extension (31 CFR 501). The rule also standardises legal-services general-license language across programs — removing legacy letter-of-engagement prerequisites in certain parts (e.g., 31 CFR 594, 597), updating 31 CFR 549 (Lebanon) and 31 CFR 576 (Iraq Stabilization and Insurgency) to remove the requirement that payments for authorised legal services be separately specifically licensed, and harmonising the 31 CFR 591 (Venezuela-related) authorisation language. The rule was effective 19 December 2024 with an applicability date of 12 March 2025.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register (89 FR 84472–84474, FR Doc 2024-24524) three general licenses issued under the Western Balkans Stabilization Regulations (31 CFR Part 588): GL 3A, GL 4, and GL 5. All three were originally issued on 18 June 2024 concurrent with OFAC's expansion of Republika Srpska / Dodik-network designations; the 23 October 2024 Federal Register notice formalises them per the Administrative Procedure Act notice requirements. GL 3A (which superseded GL 3 of 16 November 2023) authorises transactions involving certain WBSR-blocked entities that are ordinarily incident and necessary to the exportation or re-exportation of agricultural commodities, medicine, medical devices, replacement parts and components, software updates, or activities involving medical prevention, diagnosis, treatment, or clinical trials. GL 4 authorises wind-down transactions with entities blocked on 18 June 2024 through a defined cutoff. GL 5 authorises transactions ordinarily incident and necessary to the manufacture, distribution, operation, installation, or maintenance/repair of drinking-water pumps manufactured or distributed by the WBSR-blocked Bosnian Serb entity Kaldera Company EL PGP d.o.o. (and 50%-or-more-owned subsidiaries), preserving municipal water supply continuity.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register (89 FR 16400, FR Doc 2024-04856) two general licenses issued under the Western Balkans Stabilization Regulations (31 CFR Part 588): GL 2 and GL 3. Both were originally issued on 16 November 2023 concurrent with OFAC's initial round of Republika Srpska / Dodik-network designations; the 7 March 2024 Federal Register notice formalises them per the Administrative Procedure Act notice requirements. GL 2 authorises wind-down transactions with newly blocked WBSR entities through 15 March 2024. GL 3 authorises exports and re-exports of agricultural commodities, medicine, medical devices, replacement parts, and services for medical prevention and treatment to WBSR-blocked persons; GL 3 was subsequently superseded by GL 3A on 18 June 2024.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register (89 FR 15769, FR Doc 2024-04500) renaming the Darfur Sanctions Regulations (31 CFR Part 546) to the Sudan Stabilization Sanctions Regulations and amending them to implement Executive Order 14098 of May 4, 2023. E.O. 14098 broadened US sanctions authority beyond the Darfur-specific frame to cover all persons destabilising Sudan and undermining democratic transition, responding to the SAF–RSF armed conflict that erupted in April 2023. The rule adds new general licenses covering legal-service payments (§ 546.508), African Union transactions (§ 546.511), and agricultural/medical exports (§ 546.513), and introduces an interpretative provision clarifying that entities are not automatically blocked solely because a blocked individual holds a leadership position.