On Dec. 19, OFAC issued final rule relating to legal services payments.
OFAC issued final rule amending multiple CFR provisions to update general licenses authorizing payments for legal services from funds originating outside United States.
The final rule makes amendments replacing the reporting requirement in the general license with a recordkeeping requirement in applicable parts of 31 CFR Chapter V.
Requirement in the general license to submit annual reports for payments received.
With a requirement to retain for ten years records with details of payments received.
Updates general licenses authorizing provision of certain legal services, adds general license authorizing payment for legal services from funds originating outside the US.
Removes the requirement for a letter of engagement prior to receiving payment.
Effectiveness
Final rule is effective Dec. 19, 2024, and applicability date is Mar. 12, 2025.