OFAC Issues GL 35

On September 11, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) formally published General License 35 in the Federal Register, making the license part of the official regulatory record[1]. The license is issued pursuant to two distinct regulatory frameworks: the Global Terrorism Sanctions Regulations and the Illicit Drug Trade Sanctions Regulations[1]. The notice also confirms that the same general license had been previously posted on OFAC’s public website, indicating that the publication serves to codify an already accessible policy instrument[1]. By placing the license in the Federal Register, Treasury ensures that the licensing terms are transparent and enforceable under U.S. law.

Understanding GL 35 requires awareness of the two sanctions regimes referenced in the notice. The Global Terrorism Sanctions Regulations target individuals, entities, and governments designated for supporting terrorism, while the Illicit Drug Trade Sanctions Regulations focus on actors involved in the international narcotics trade[1]. A general license, as opposed to a case‑by‑case license, provides a blanket authorization for certain activities that would otherwise be prohibited under these sanctions. The document does not detail the specific activities covered, but its issuance signals that Treasury has identified a category of transactions it wishes to expressly permit without further individual review[1].

Strategic Rationale Behind GL 35

The decision to issue a new general license suggests Treasury is seeking to streamline compliance for actors whose transactions fall within a narrowly defined, policy‑approved scope. By codifying the authorization in a general license, OFAC reduces the administrative burden on both regulated parties and the Agency, allowing resources to focus on higher‑risk enforcement actions. The timing of the publication—immediately following the license’s online availability—indicates an intent to provide legal certainty to businesses and financial institutions that may be navigating complex sanctions landscapes. This approach aligns with a broader Treasury strategy of using targeted, rule‑based tools to manage the economic dimensions of national security threats.

Moreover, the dual regulatory basis of GL 35 reflects an integrated view of terrorism financing and illicit drug trafficking as interconnected challenges. By linking the two regimes in a single licensing instrument, OFAC underscores the overlapping nature of these illicit networks and the need for coordinated policy responses. The general license therefore functions as both a practical facilitation device and a symbolic statement that the United States continues to adapt its sanctions architecture to evolving threat dynamics.

Regional and Policy Implications

Formalizing GL 35 will likely affect cross‑border financial flows that intersect with the terrorism and drug‑trade sanctions regimes. Entities operating in jurisdictions where designated persons or groups are active will need to reassess their transaction structures to ensure they fall within the newly authorized parameters. Banks, exporters, and humanitarian organizations may find that certain previously ambiguous dealings are now clearly permissible, potentially easing commerce and aid delivery in high‑risk regions. Conversely, the license may also sharpen enforcement focus on activities that remain outside its scope, prompting tighter due‑diligence practices.

On a broader policy level, GL 35 reinforces the United States’ reliance on economic statecraft to deter financing of terrorism and illicit narcotics. By expanding the toolbox of authorized actions, Treasury signals its commitment to maintaining pressure on prohibited actors while offering limited relief to legitimate participants. This balance supports diplomatic objectives that combine deterrence with engagement, especially in areas where cooperation with local partners is essential to disrupt illicit financing networks.

Unresolved Issues and Future Signals

The Federal Register notice does not disclose the specific categories of transactions or the precise criteria that qualify for the general license, leaving stakeholders to await further guidance or interpretive releases from OFAC. Until the detailed terms are clarified, firms must exercise caution and may seek individual licenses for borderline activities. Future updates—such as amendments to GL 35 or the issuance of additional general licenses—would indicate a shift in Treasury’s assessment of the underlying threats or a response to feedback from the regulated community. Monitoring OFAC’s subsequent communications will be critical for gauging how this licensing approach evolves and what it reveals about U.S. sanctions priorities.