A specific license is a case-by-case authorization issued by the US Department of the Treasury's Office of Foreign Assets Control (OFAC) that allows a particular person or entity to engage in a transaction that would otherwise be prohibited under US economic sanctions. It is distinguished from a general license, which is a blanket authorization published by OFAC permitting a defined category of transactions without requiring individual application.
Specific licenses are issued under the authority of statutes such as the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act, and are governed procedurally by 31 C.F.R. Part 501. Applicants must submit a detailed request—typically through OFAC's online licensing portal—identifying the parties, jurisdictions, goods or services, financial flows, and the policy rationale for authorization. OFAC consults with the State Department and other agencies, especially when foreign policy equities are involved.
Common categories of specific license applications include:
- Humanitarian transactions with sanctioned jurisdictions (e.g., medical equipment to Iran, Syria, or North Korea beyond what general licenses already permit).
- Legal fees and representation for blocked persons.
- Unblocking of frozen funds where the underlying interest belongs to a non-sanctioned party.
- Wind-down activity following the designation of a new Specially Designated National (SDN).
- Journalistic, academic, or NGO operations in restricted zones.
Issuance is discretionary. OFAC may impose conditions, reporting requirements, or expiration dates, and may revoke licenses if circumstances change. Operating outside the scope of a specific license can trigger civil penalties under IEEPA (currently in the range of roughly USD 370,000 per violation or twice the transaction value, whichever is greater, adjusted annually for inflation) and potential criminal liability.
For researchers and MUN delegates, specific licenses are useful evidence of how the US calibrates sanctions enforcement—balancing maximum-pressure policy against humanitarian, legal, and diplomatic exceptions on a transaction-by-transaction basis.
Example
In 2022, OFAC issued specific licenses to several US law firms authorizing them to provide legal representation to sanctioned Russian oligarchs challenging their designations, despite the broader Russia-related sanctions program.
Frequently asked questions
A general license is published by OFAC and automatically authorizes a category of transactions for anyone meeting its terms. A specific license is granted only to the named applicant for the described transaction, after an individual application and review.
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