International Law Advisory - OFAC Issues General License for Libyan Sanctions Regulations

On Friday, April 2, 2004, the Office of Foreign Assets Control (“OFAC”) issued a new general license authorizing certain types of travel and residence transactions related to Libya.  The general license has been added to the Libyan Sanctions Regulations, 31 C.F.R. § 550.574, and it supersedes § 550.560 of the regulations.

Under the general license, U.S. persons may engage in transactions related to travel to, from, and within Libya, and residence within Libya. U.S. travel service providers may book travel to, from or within Libya, and arrange accommodations within Libya for U.S. persons.  Except as expressly authorized, the general license does not authorize any transactions prohibited by § 550.203 of the Libyan Sanctions Act, such as flights to or from Libya by U.S. air carriers.

Payment for these transactions must be made in cash, by debit, or by credit to accounts at banks that are not in Libya or entities of the Libyan government.  U.S. persons may pay for these transactions with U.S.-issued credit cards only if the transactions are with non-Libyan carriers.  The form of payment by U.S. persons to U.S. travel providers is not restricted.  U.S. persons in Libya may open and maintain accounts at Libyan financial institutions for personal maintenance, residence, and travel-related expenses.  The personal accounts may be funded only in cash or from accounts maintained at banks that are neither U.S. persons nor entities of the Government of Libya.  The general license does not authorize any debit to a blocked account, nor does it authorize transfer of blocked property.

Finally, the general license authorizes the importation into the U.S. of Libyan-origin personal effects, including gifts of limited value, provided that the items are not intended for resale or otherwise prohibited from importation.

For a copy of the general license, please click here.  We will continue to keep you advised of sanctions and export control developments.  If you have any questions, please feel free to contact Ed Krauland at 202.429.8083 or Meredith Rathbone at 202.429.6437.