The VSR also identify limited general licenses authorizing otherwise restricted activities. For instance, licenses exist for the provision of certain legal services to blocked parties and for the withdrawal of normal service charges by U.S. financial institutions from blocked accounts.
As noted above, OFAC considers these regulations to be preliminary and intends to supplement the VSR with a more comprehensive set of regulations. The next iteration of the VSR will apparently include “additional interpretative and definitional guidance and additional general licenses and statements of licensing policy.”