Yes, it is. I may soon have to consider changing Sanctionlaw.com to Libyagenerallicenses.com at the rate which the United States Department of the Treasury Office of Foreign Assets Control (OFAC) is issuing general licenses to authorize transactions previously prohibited by the Libyan sanctions.

On Friday OFAC issued Libya General License 8a. This new general license supersedes General License No. 8 issued on September 19, 2011 and authorizes all transactions involving the Government of Libya, its agencies, instrumentalities, and controlled entities, and the Central Bank of Libya, provided that (1) all funds, including cash, securities, bank accounts, and investment accounts, and precious metals previously blocked pursuant to U.S. sanctions against Libya remain blocked with the exception of those provided in Libya General License No. 7A; and (2) the transactions do not involve any persons listed in the Annex to General License 8a.​​​​​​​​​​​​​

All jokes aside, I do see this latest action as a positive development. I applaud OFAC for quickly issuing general licenses to match international developments in easing sanctions on Libya. This easing of sanctions is evidenced by this past week’s lifting of sanctions against Libya by both the UN and the EU. Despite these new developments, however, there are still parties blocked pursuant to the Libya sanctions and all compliance programs should be scanning for such individuals and taking appropriate steps to avoid transactions with them.

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.