OFAC General License

A general license (GL) is a regulatory instrument issued by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) that authorizes a defined class of transactions that would otherwise violate U.S. economic sanctions. Unlike a specific license, which is granted to a named applicant after individual review, a general license is published openly and may be relied upon by any person whose conduct falls within its terms.

General licenses are typically embedded in the relevant sanctions regulations in 31 C.F.R. Chapter V or posted on OFAC's website alongside the sanctions program they modify. They commonly serve to:

• Carve out humanitarian activity, such as the export of food, medicine, and medical devices.
• Authorize wind-down periods after a new designation, giving counterparties time (often 30–45 days) to divest or terminate contracts with a newly listed Specially Designated National (SDN).
• Permit specific sectors, such as agricultural trade with Iran, telecommunications and internet services, or journalistic activity.
• Enable legal, NGO, and diplomatic functions, including payment of attorneys' fees and operations by international organizations.

Reliance on a GL is conditional: a user must satisfy every term, keep records (generally five years under 31 C.F.R. § 501.601), and may still need to file reports with OFAC. Activities outside the scope require a specific license or remain prohibited. OFAC frequently amends, reissues, or revokes GLs as policy shifts; practitioners track these through OFAC's Recent Actions feed and accompanying FAQs, which carry interpretive weight though they are not regulations themselves.

Because sanctions liability under statutes like IEEPA is strict, misreading a GL's scope can trigger civil penalties even absent intent. For that reason, compliance officers, banks, and humanitarian groups treat GL language with the same care as treaty text.