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On September 19, 2011, the U.S.
Department of Treasury's Office of Foreign Assets Control ("OFAC")
continued to ease the sanctions imposed on Libya by issuing new General
Licenses No. 7A and No. 8. In general, the new licenses allow U.S.
persons to engage in transactions with the Government of Libya, its agencies,
instrumentalities, and controlled entities and the Libyan National Oil
Corporation ("NOC") itself. The licenses also unblock property and
interests in property of the NOC and entities it owns or controls. However,
assets of other Libyan Government owned or controlled entities which were
blocked prior to the issuance of the new licenses remain blocked, and
transactions with designated persons associated with the former Gaddafi regime remain
General License No. 7A replaces and
supersedes General License No. 7, dated September 9, 2011. Specifically,
General License No. 7A authorizes U.S. persons to engage in all transactions
involving the NOC or entities owned or controlled by the NOC, provided that
such transactions do not involve any other persons whose property and interests
in property remain blocked. This is a significant change from General License
No. 7, which had only authorized U.S. persons to engage in transactions involving
certain entities owned or controlled by the NOC but not with the NOC itself.
Transactions with the following list
of NOC owned or controlled entities are specifically authorized:
General License No. 7A also unblocks
all property and interests in property of the NOC and entities owned or
controlled by the NOC. However a report must be filed with the Sanctions
Compliance and Evaluation Division of OFAC within 10 business days of the
release of any blocked funds, including cash and securities.
General License No. 8 signals the
U.S. Government's recognition of the fall of the Gaddafi regime in Libya by
authorizing U.S. persons to engage in all transactions involving the Government
of Libya, its agencies, instrumentalities, and controlled entities, and the
Central Bank of Libya. However, all assets of Libyan Government owned or
controlled entities (other than the NOC entities that were unblocked in General
License No. 7A) which were blocked on or before September 19, 2011 remain
blocked and all transactions with designated individuals and entities of the
former Gaddafi regime listed on the Annex to General License No. 8 remain
General License No. 7A and General
License No. 8 reflect OFAC's continued policy of reducing the sanctions imposed
on Libya under Executive Order 13566 as the Transitional National Council
forces continue to consolidate control over Libya.
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