Issuance of Counter Terrorism General License and Amended Frequently Asked Question

The Office of Foreign Assets Control (OFAC) has published a press release informing about new sanction measures. Specifically, in a first step, the Office has issued a new General License (GL 21B) to permit (financial) transactions that are necessary to provide „Limited Safety“ in connection with specified sanctioned vessels (e.g. emergency repairs, actions necessary to provide the safety of crew members, etc.) that would otherwise be prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594. The License thereby requires that any payments to a „blocked person must be made into a blocked account“.
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In a second step, OFAC has updated one frequently asked question, FAQ 1097 to clarify just which transactions are authorized under the new General License described above. The FAQ reads as follows – as quoted:
1097. What does Counterterrorism-related General License 21B (GL 21B) authorize?
GL 21B authorizes all activities otherwise prohibited by the Global Terrorism Sanctions Regulations (GTSR), 31 CFR part 594, that are ordinarily incident and necessary to the limited safety and environmental activities described in paragraph (a) of GL 21B involving certain blocked persons and vessels through 12:01 a.m. eastern daylight time, April 13, 2023. GL 21B does not authorize the offloading of any cargo onboard any of the blocked vessels listed in GL 21B, and any payment of claims to or for the benefit of any blocked persons or vessels would require a specific license from OFAC.
After the expiration of GL 21B, U.S. persons will be prohibited from engaging in any transactions with the blocked persons or vessels listed in GL 21B, unless otherwise exempt or authorized by OFAC. U.S. persons unable to conclude transactions authorized by GL 21B before 12:01 a.m. eastern daylight time, April 13, 2023, are encouraged to seek guidance from OFAC.
Non-U.S. persons, including foreign financial institutions, generally do not risk exposure to sanctions for engaging in transactions with blocked persons where those transactions would not require a specific license if engaged in by a U.S. person. Non-U.S. persons unable to conclude transactions authorized by GL 21B before 12:01 a.m. eastern daylight time, April 13, 2023, are encouraged to seek guidance from OFAC.