ffective as of December 2008, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has expanded its scope of mandatory licensing affecting legal services available under the Global Terrorism Sanctions Regulations and payment for legal services under the Foreign Terrorist Organizations Sanctions Regulations.

“Any payment of professional fees and reimbursement of incurred expenses must be officially licensed,” OFAC’s notice in the federal register said. OFAC disperses licenses at their discretion. The licenses also authorize the initiation and conduct of proceedings.