General Licence

What a general licence actually is

A general licence is a broad authorisation OFAC issues covering a defined category of transactions that would otherwise violate US sanctions regulations. Unlike a case-by-case authorisation, a general licence applies automatically to anyone whose activity falls within its published terms, without requiring that person or firm to submit anything to OFAC first. If your transaction genuinely fits the licence’s stated scope and conditions, it’s authorised the moment it happens, not after some future approval.

The legal basis: 31 CFR 501.801 and program-specific rules

General licensing procedures are governed by 31 C.F.R. § 501.801, which permits OFAC to issue general licences authorising specific categories of transaction under appropriate terms and conditions, including for sanctions programmes not yet formally codified in the regulations. Individual sanctions programmes carry their own specific general-license provisions too, for example, 31 C.F.R. § 555.307 for the Iran program and § 542.313 for Syria, each defining a general licence as any authorisation whose terms are set out in that programme’s own Subpart E or published directly on OFAC’s website.

Why it doesn’t require applying to OFAC at all

This is the core practical distinction from a specific licence: a general licence is self-executing. General licences are published in the Code of Federal Regulations, made available directly on OFAC’s own website, or published in the Federal Register, and anyone whose activity matches the published terms can rely on it directly. There’s no application, no waiting period, and no case-specific approval to obtain, which is precisely why general licences exist for categories of transaction OFAC has already decided, as a matter of policy, are low-risk or consistent with broader US objectives, humanitarian aid, certain educational exchanges, and personal remittances among the most common categories.

The “squarely” standard: why close enough isn’t enough

A transaction has to align precisely with a general licence’s specific language and every attached condition; approximate or good-faith compliance with the general spirit of a licence isn’t the same as meeting its actual terms. If a transaction falls even slightly outside what the licence’s wording actually covers, the general licence provides no protection at all for that transaction, regardless of how reasonable the underlying activity might otherwise seem. This precision requirement is exactly why firms operating near a general licence’s boundary often still consult sanctions counsel before proceeding, rather than assuming a favourable reading will hold up.

A real, current example

OFAC’s Venezuela sanctions programme illustrates how specific and dated these authorisations actually are: General License 48, titled “Authorizing the Supply of Certain Items and Services to Venezuela,” is a real, currently referenced authorisation permitting a defined category of transactions that would otherwise be prohibited under the broader Venezuela sanctions regime. Each general licence like this one carries its own number, its own precise scope, and its own conditions, and firms need to check the specific, current version rather than assuming an older reference to a similarly-named licence still reflects the exact terms in force today.

The reporting trap most people miss

Some general licences aren’t unconditional even once you fit within their terms. OFAC’s own regulations state directly that persons relying on certain general licences may be required to file reports and statements according to that licence’s specific instructions, and that failing to file all required information on time can nullify the authorisation the general licence otherwise provided, converting what looked like a fully authorised transaction into an apparent violation after the fact. A firm that correctly identifies an applicable general licence, but then misses an attached reporting deadline, can end up worse off than if it had never relied on the licence at all.

What a general licence does NOT do

A general licence, however broad its terms, doesn’t remove a blocked person from the SDN List or lift a country’s underlying sanctions programme generally. It authorises a specific, defined category of otherwise-prohibited transaction with that party or under that programme; the underlying designation and the broader restrictions around it remain fully in place for everything the licence doesn’t specifically cover. Treating a general licence as a general clearance to deal with a blocked party across the board, rather than strictly within the licence’s own defined scope, is a genuine and consequential misreading.

Where to actually find current general licences

General licences appear in three places: Subpart E of the specific sanctions programme’s own regulations in the Code of Federal Regulations, OFAC’s own website, which publishes current, active licences directly, and the Federal Register, where new or amended general licences get formally announced. Given how frequently OFAC issues, amends, and expires specific general licences, particularly for fast-moving programmes like Russia, Venezuela, and Iran, checking OFAC’s own current listing directly is the only reliable way to confirm a licence a firm is relying on is still active in its original form.

General licence vs specific licence: the rule that decides which applies

OFAC’s own stated policy resolves the relationship between the two licence types directly: it will not grant a specific licence application for a transaction already covered by an existing general licence. If a general licence applies to your situation, that’s the authorisation path available; a specific, individually-requested application for the same activity will simply be declined, since OFAC has already addressed that category of transaction through the general licence itself.

Getting this right in a compliance programme

A compliance programme handling general licence reliance well maintains a current, actively monitored list of which general licences apply to its specific business activities, checks OFAC’s published terms directly, and re-verifies them before every reliance rather than assuming a licence checked once remains unchanged, tracks any attached reporting obligations with the same discipline applied to other regulatory deadlines, and documents the precise licence provision relied upon for every transaction, so that if a transaction is later questioned, the firm can show exactly which licence, which terms, and which conditions it believed applied at the time.

Frequently asked questions

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