If I am designated under a country-based sanctions program rather than the SDN List, what are my options? - Intercollegium Law Firm
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If I am designated under a country-based sanctions program rather than the SDN List, what are my options?

Country-based designations, such as those under the Venezuela-related or Cuba sanctions programs affecting regional business partners, operate differently than SDN listings. Sectoral sanctions may permit certain licensed activities, and OFAC issues specific licenses authorizing otherwise prohibited transactions. Argentine and Chilean companies caught in secondary sanctions exposure can apply for specific licenses demonstrating humanitarian purpose, wind-down necessity, or minimal sanctions nexus. General licenses published in program annexes may already authorize your particular transaction category. License applications typically receive responses within 90–120 days, though expedited processing exists for demonstrated urgency.

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