2024-12-19 | 2024-30344The Department of the Treasury’s Office of Foreign Assets Control issued a final rule amending multiple 31 CFR parts to update general licenses authorizing payments for legal services from funds originating outside the United States. The rule replaces annual reporting requirements with a ten-year recordkeeping obligation for U.S. persons receiving such payments and adds new general licenses in specific sanction regimes to authorize these payments. Additionally, the regulation simplifies language and removes prior requirements for letters of engagement or specific licensing for certain legal service payments to conform with current standards.