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ARTICLE · 04 MAY 2011

Treasury/OFAC Issues General License No. 5

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As referenced in our February 28 and April 12, 2011 advisories, the United Nations Security Council adopted Resolution 1970 (2011) in response to the Qadhafi regime’s actions against political protestors and the civilian population in Libya.

United StatesInternational Law
Edward Krauland
Edward Krauland
Jack Hayes
Jack Hayes
Meredith Rathbone
Meredith Rathbone

License Authorizes Transactions Relating to Certain Oil, Gas or Petroleum Products Exported From Libya

As referenced in our February 28 and April 12, 2011 advisories, the United Nations Security Council adopted Resolution 1970 (2011) in response to the Qadhafi regime's actions against political protestors and the civilian population in Libya. The most recent OFAC license, General License No. 5, grants certain exemptions to the sanctions imposed by Executive Order 13566 of February 25, 2011.

OFAC issued General License No. 5 on April 26, 2011. It allows US persons to engage in transactions with Qatar Petroleum and the Vitol group of companies related to oil, gas, or petroleum products that are exported from Libya, in accordance with the Transitional National Council of Libya ("TNC"), as long as neither the Libyan Government nor any individual with blocked property and interests benefits from such transactions. General License No. 5 does permit transactions with the Arab Gulf Oil Company ("Agoco"), which is an entity operating in areas controlled by TNC and under the auspices of TNC. OFAC also issued a Statement of Licensing Policy on April 26, which allows US persons to request from OFAC permission to trade in and support or facilitate trade in hydrocarbon fuel (i.e., oil, gas, and petroleum products), to the extent that such hydrocarbon fuel is exported under the auspices of TNC. US persons also may request specific licenses to participate in transactions related to the production of oil, gas, and petroleum products in areas under TNC control.

Within 30 days of the transactions, any US persons purchasing oil, gas, or petroleum products from Qatar Petroleum or the Vitol group of companies in accordance with this license must submit a report to OFAC detailing these transactions. Among other things, the reports must include information regarding due diligence mechanisms used to verify that neither the Government of Libya nor any other person whose property and interests in property are blocked, with the exception of Agoco, benefits from such transactions.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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