Pursuant to a Freedom of Information Act (FOIA) Request, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a list of parties holding OFAC licenses under a variety of different sanctions programs. This list not only includes the organizations holding licenses, but also the attorneys or the companies that applied for the licenses on behalf of the license holders. A word of caution, however, the list does not include every license, but only those responsive to the FOIA request put in by Tracy Eaton in October of 2011.

For years, organizations and individuals have been asking for a “whitelist” of entities who hold valid OFAC licenses. Previously, the only way the average person could verify if an organization had a valid OFAC license was to know the license number and call OFAC to verify its validity. Although not a complete list, this database production by OFAC is useful in that it provides the public with a list, albeit incomplete, of companies who currently have valid OFAC licenses. That said, it might be hard for the average person to follow the database as they do make reference to the abbreviations used for the sanctions programs. So if the person reading the database does not know that “IA” is the abbreviated notation for a license issued pursuant to the Iranian Transactions Regulation (ITR) or that “SDGT” represents a license granted under the Global Terrorism Sanctions then they may have a hard time understanding what the licenses where granted for.

The database also reveals a lot of interesting information. Two of the more interesting license applications were put in by U.S. government agencies. First, the United States Department of State, Office of Terrorism Finance and Economic Sanctions Policy–who advise OFAC on license applications–applied for a license on behalf of Citigroup under the new Libya Sanctions program. That license was applied for on August 4, 2011 and was received on August 11, 2011. Incidentally, there license has no expiration date. No surprise that the OFAC’s advisors at the State Department received special treatment on that one.

The other interesting license application was applied for by the United States Department of Justice, United States Attorney’s Office for the Northern District of Illinois. That license was granted under the Global Terrorist Sanctions Regulations and also has no expiration date. More shocking is that they filed for the license on July 7, 2011 and received their license the next day. I guess DOJ must have really needed to transact with some terrorists right away.

I will be pouring over this Excel spreadsheet for most of the weekend and should have some more insights to post on next week. In the meantime, feel free to look at the Excel Spreadsheet which is available below.

PARTIAL OFAC LICENSING DATABASE*

[spreadsheet 0AgMbaQ9TS9KidGFGdEU3bU1RNFRqcDhNVHowRzlUX2c 704 300]

*This list has been modified from its original version. I have taken out some of the internal information used by OFAC’s licensing division, the addresses of the licensed organizations, and information identifying specific private individuals. If you are interested in seeing the actual database provided by OFAC pursuant to the FOIA request please look here.

**Special thanks to our friend Rob Sequin from Havanajournal.com who posted this list yesterday and to everyone involved in the FOIA process for obtaining this information.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.