OFAC General License Numbering Convention

The OFAC General License Numbering Convention is the administrative system by which the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) catalogues the authorizations it issues under sanctions programs administered pursuant to the International Emergency Economic Powers Act (IEEPA, 50 U.S.C. §§ 1701–1708), the Trading with the Enemy Act (50 U.S.C. §§ 4301 et seq.), and program-specific statutes such as the Countering America's Adversaries Through Sanctions Act (CAESA, Pub. L. 115-44). General licenses (GLs) are blanket authorizations published under the regulatory authority delegated to the Secretary of the Treasury by Executive Order, most commonly through the Reporting, Procedures and Penalties Regulations at 31 C.F.R. Part 501 and the specific program parts of 31 C.F.R. Chapter V. The numbering convention is not codified in statute; it is an internal OFAC practice that has evolved to permit rapid issuance, amendment, and tracking of authorizations during fast-moving sanctions episodes.

Procedurally, each general license is assigned a sequential integer within its parent sanctions program, prefixed by "GL" (e.g., "Russia-related GL 8"). When OFAC modifies the scope, duration, or counterparties of an existing authorization, it issues a successor instrument bearing the same root number with a letter suffix indicating the revision generation — GL 8A, GL 8B, GL 8C, and so forth. The successor expressly supersedes its predecessor in the operative text, typically in the final paragraph, and the predecessor is then archived to OFAC's "Legal — General Licenses" web repository with a strike-through or "superseded" notation. Practitioners must therefore cite both the root number and the live letter suffix, since reliance on a superseded GL provides no defense to enforcement under 31 C.F.R. § 501.601.

Variants of the convention appear across programs. Cuba (31 C.F.R. Part 515) and Iran (31 C.F.R. Part 560) historically embed many general licenses directly into the regulatory text rather than issuing them as standalone web-posted instruments, so authorizations there carry C.F.R. citations (e.g., § 515.560) rather than GL numbers. Program-specific prefixes are used where a single Executive Order spawns multiple distinct regimes: GLs issued under the Venezuela program reference the Venezuela Sanctions Regulations (31 C.F.R. Part 591), while those issued under E.O. 14024 are styled "Russia-related." When OFAC needs to wind down an entire designation, it issues a high-numbered wind-down GL with a defined expiration date stated in the body; expiration is by calendar date, not by suffix, and an extension is published as the next letter suffix.

Contemporary examples illustrate the system in operation. Following the February 2022 expansion of Russia sanctions, OFAC issued Russia-related General License 8, authorizing certain energy-related transactions with named Russian financial institutions; the authorization has been reissued repeatedly as GL 8A, 8B, 8C, and onward, with each iteration narrowing or extending the scope and counterparty list. In the Venezuela program, GL 41, issued by OFAC on 26 November 2022, authorized Chevron Corporation to resume limited operations with Petróleos de Venezuela, S.A. (PdVSA); it was subsequently revoked and replaced by GL 41A in 2024 following the Maduro government's failure to honor electoral commitments. Treasury's Syria GLs issued after the January 2025 fall of the Assad government, and Cuba-related authorizations modified across the Obama, Trump, Biden, and second Trump administrations, follow the same suffix discipline.

The convention should be distinguished from specific licenses, which are case-by-case authorizations issued to a named applicant under 31 C.F.R. § 501.801(b) and bear an internal case number rather than a public GL designation. It is also distinct from FAQs published on the OFAC website, which provide interpretive guidance but confer no authorization and create no safe harbor. Statements of Licensing Policy — favorable consideration commitments for specific-license applications — likewise carry no GL number. Finally, the convention differs from the Commerce Department's Bureau of Industry and Security (BIS) license exception nomenclature (e.g., License Exception STA, GBS) under the Export Administration Regulations (15 C.F.R. Parts 730–774), which governs dual-use exports rather than blocked-property transactions.

Edge cases occasionally complicate the system. OFAC has on rare occasions issued a GL bearing the same number under two different programs simultaneously, requiring practitioners to specify the program prefix. When a sanctions program is consolidated or terminated — as occurred with the Sudan program in 2017 — outstanding GLs lapse with the regulatory revocation, though their texts remain on the OFAC archive for reference in legacy compliance audits. Controversy has arisen over OFAC's practice of issuing "JL" joint licenses with the United Kingdom's Office of Financial Sanctions Implementation (OFSI) and the EU; these are coordinated but not technically governed by the GL numbering convention. Researchers have also noted that the speed of suffix issuance during the Russia program — exceeding twenty amendments to certain root GLs within two years — has strained traditional compliance-screening workflows.

For the working practitioner, fluency in the numbering convention is operationally essential. Bank compliance officers, corporate counsel, humanitarian NGOs, and foreign-ministry sanctions desks must cite the live letter suffix in transaction memoranda, attestation packages, and counterparty disclosures; reliance on a stale version exposes the institution to civil penalties under 50 U.S.C. § 1705 of up to the greater of $377,700 (as adjusted) or twice the value of the transaction. Diplomats engaged in licensing diplomacy — pressing Treasury for humanitarian carve-outs, energy wind-downs, or third-country exemptions — must frame requests in terms of GL amendment or successor issuance. Mastery of the convention is, in short, the entry point to substantive engagement with the U.S. sanctions architecture.