July 2014 will go down as the month The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) did some major housekeeping. In the last week or so, OFAC has issued three new sets of regulations. Not bad considering two of those days were the weekend, and one was the July 4th holiday. In the past week, OFAC has published new regulations for South Sudan, and Burma, both which I have already posted on. Today saw the publishing of the new Central African Republic Sanctions Regulations (“CARSR”) which implements Executive Order (“E.O.”) 13667 issued on May 12, 2014. These regulations are pretty bare bone, however, OFAC has promised that it intends to supplement these regulations–found at 31 C.F.R. Part 553–at a later date. Due to this fact, OFAC has kept the language of the E.O. 13667 in the regulations as Appendix A until such time as it updates the regulations.

There’s nothing too crazy to report on these new regulations. On their face they seem to contain the standard language we find in many of the specifically targeted sanctions programs. Like the new Burma, and South Sudan regulations announced last week, OFAC has continued the practice of allowing receipt of payment of legal fees and reimbursement of expenses from unblocked sources so long as as a copy of a signed engagement letter or legal services entered into with the U.S. lawyer or law firm is submitted to OFAC. This obviates the need to wait around for an OFAC specific license to get paid for legal services rendered under the general license contained at 31 C.F.R. 553.506. Another thing I noticed is that OFAC has started to define OFAC within the Subpart C’s, the traditional subpart for definitions in the various sanctions regulations. I’m not entirely sure why that’s necessary. I’m pretty sure if anyone has dug deep enough to discover the regulations they know what OFAC is, but then again with some of the things I’ve heard over the course of my career…..maybe not.

One thing that I will say in this post that may (or may not) add value, is that OFAC has really been on the ball lately. They have been issuing licenses faster than usual, have been responsive to email communications, have been accessible by telephone, and have been knocking out new sets of regulations left and right. This is particularly surprising since there has been a fairly high turn over rate this year with many long time OFAC employees leaving for the private sector. Last I heard they were having some troubles bringing on new employees due to delays in the security clearance processing, but you wouldn’t know it based on the speed at which they seem to be operating. Now if they could just issue an opinion on that Request for Interpretative Guidance I filed in March of 2013…..