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Lebanon’s Sanctions Screening Regulations: A Guide for Compliance

The United States has imposed sanctions on Lebanon, targeting individuals and entities undermining its sovereignty or democratic processes. To ensure compliance with these regulations, it is essential to understand the legal framework and guidelines set forth by the Office of Foreign Assets Control (OFAC).

Sanctions Brochures

OFAC has published brochures providing an overview of its regulations regarding Lebanon-related sanctions. These quick-reference tools are useful for businesses and individuals seeking to navigate the complex regulatory landscape.

Frequently Asked Questions

OFAC has compiled hundreds of FAQs about its sanctions programs and related policies, covering topics such as:

Licensing
Blocked funds
Legal fees

The full list of FAQs is available online.

Interpretive Guidance

The OFAC issues guidance on specific issues related to sanctions programs, addressing complex topics and responding to public requests for clarification. This guidance helps ensure compliance with regulations and provides businesses with clarity on what is permissible.

Applying for an OFAC License

In some cases, it may be in the best interest of both parties to authorize specific economic activities restricted by Lebanon-related sanctions. The OFAC license application process allows individuals and businesses to request permission to engage in transactions that would otherwise be prohibited.

Guidance on OFAC Licensing Policy

The OFAC has issued guidance on licensing policies related to Lebanon-related sanctions, including:

Release of blocked funds for legal fees
Costs incurred in challenging the blocking of US persons

Businesses should consult this guidance to ensure compliance with regulations.

The Lebanon-related sanctions represent the implementation of multiple legal authorities, including:

Executive orders
Public laws
OFAC regulations

These authorities are codified in the Code of Federal Regulations (CFR) and posted in the Federal Register.

Executive Orders

Some of these authorities are in the form of executive orders issued by the President, such as:

Executive Order 13441: Blocks property of persons undermining Lebanon’s sovereignty or democratic processes

Statutes

Other authorities are public laws passed by Congress, including:

International Emergency Economic Powers Act (IEEPA)
National Emergencies Act (NEA)

Code of Federal Regulations and Federal Register Notices

The OFAC regulations implementing these legal authorities can be found in 31 CFR Part 549 Lebanon Sanction Regulations. Recent changes to these regulations have been published in the Federal Register, including amendments to general licenses for humanitarian activities and official business. Businesses should regularly check the Federal Register for updates on sanctions regulations.

Conclusion

By understanding the legal framework and guidelines set forth by OFAC, businesses and individuals can ensure compliance with Lebanon-related sanctions and avoid potential penalties.