Dr. Shaun Gregory Morgan is a leading OFAC license application lawyer in Dubai, with 15+ OFAC specific licenses approved for UAE clients across Iran, Russia, Cuba, and other US sanctions programs. Senior-partner counsel from Emirates Towers, Level 42, with direct OFAC engagement experience.
OFAC administers US sanctions programs under the authority of the International Emergency Economic Powers Act (IEEPA) and other statutes, authorizing the issuance of licenses that permit transactions otherwise prohibited by sanctions regulations. These authorizations fall into two categories: general licenses and specific licenses.
General licenses are self-executing authorizations that appear in the Code of Federal Regulations for each sanctions program. They authorize all persons meeting specified criteria to engage in defined transactions without making any application to OFAC. Common general licenses cover personal remittances, certain humanitarian transactions, emergency medical services, and information communications technology. UAE businesses should first assess whether any available general license covers the proposed transaction.
Where no general license applies, a specific license may be available. Specific licenses are individual authorizations issued by OFAC upon application, covering transaction types including humanitarian dealings (food, medicine, medical devices for sanctioned countries), wind-down authorizations (terminating pre-existing contracts), commercial transactions (specific goods or services), and emergency authorizations for time-sensitive situations. Dr. Shaun Gregory Morgan has secured more than 15 OFAC specific licenses for UAE clients across the Iran (ITSR), Russia (EO 14024), Cuba (CACR), and other sanctions programs.
Dr. Shaun Gregory Morgan advises UAE businesses on the full spectrum of OFAC specific license types — from Iran humanitarian authorizations to Russia wind-down licenses and emergency commercial approvals.
OFAC specific license applications under the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560). We prepare applications for humanitarian transactions, personal remittances, journalistic activities, wind-down authorizations, and other ITSR-permitted categories for UAE clients with Iran-nexus business.
OFAC specific license applications under Executive Orders 14024 and 14066 (Russia/Ukraine sanctions). We advise UAE businesses on applications for wind-down authorizations, energy transaction licenses, and commercial authorizations needed to exit or restructure Russia-related business relationships in compliance with OFAC regulations.
OFAC specific license applications under the Cuban Assets Control Regulations (CACR, 31 C.F.R. Part 515). We prepare applications for travel-related transactions, journalistic activities, educational exchanges, and commercial dealings for UAE entities with Cuba-nexus business requiring OFAC authorization.
OFAC specific licenses for the export or re-export of food, medicine, medical devices, and other humanitarian goods to sanctioned countries, including Iran, Cuba, North Korea, and Venezuela. Humanitarian licenses are among the most commonly approved OFAC authorizations and require detailed transactional and beneficiary documentation.
OFAC specific licenses authorizing the orderly wind-down of pre-existing contracts with newly sanctioned parties. Wind-down authorizations allow UAE businesses to exit sanctioned relationships in a controlled, compliant manner — completing pending deliveries, collecting outstanding payments, and terminating obligations within OFAC-authorized timeframes.
Expedited OFAC license applications for time-sensitive transactions where standard processing timelines are commercially unacceptable. Emergency applications require a compelling showing of necessity and urgency. Dr. Shaun Gregory Morgan's direct OFAC engagement experience allows us to present emergency applications in the manner most likely to receive expedited consideration.
From initial eligibility assessment through OFAC approval, Dr. Morgan manages every stage of the specific license application process — maximizing approval prospects and minimizing processing delays.
We conduct a thorough analysis of the proposed transaction against the applicable sanctions program, general licenses, and OFAC policy guidance to determine whether a specific license is available, likely to be approved, and the most appropriate licensing category to pursue.
We prepare a comprehensive specific license application — identifying all parties, describing the transaction in precise detail, citing the applicable legal authority, presenting the policy justification, and compiling all required supporting documentation in the format that OFAC expects.
We submit the application through OFAC's official licensing portal, ensuring that all required elements are present and complete. Incomplete or improperly formatted applications are routinely returned without action — creating costly delays that our application expertise consistently avoids.
We actively monitor application status, respond to any OFAC requests for additional information, and manage direct engagement with OFAC licensing staff through to final disposition. Upon approval, we advise on compliance with any license conditions and ongoing reporting obligations.
Dr. Shaun Gregory Morgan is one of the UAE's most experienced OFAC license application lawyers, having secured more than 15 OFAC specific licenses for UAE clients across Iran, Russia, Cuba, and other US sanctions programs. His direct OFAC engagement experience — developed over 20+ years of practice in New York and Dubai — allows him to present applications in the precise format, legal framework, and policy context that OFAC expects, maximizing approval rates and minimizing processing delays for UAE businesses seeking to access sanctioned markets through legitimate channels.
OFAC general licenses authorize categories of transactions for all persons meeting specified criteria without requiring individual application — they are self-executing and appear in the Code of Federal Regulations for each sanctions program. OFAC specific licenses, by contrast, are individual authorizations issued by OFAC to a particular applicant for a particular transaction or set of transactions. Specific licenses are required when a transaction does not qualify under any available general license. An OFAC license application lawyer in Dubai can assess which pathway applies to your specific transaction and program.
UAE businesses may apply for OFAC specific licenses across a range of categories, including: humanitarian licenses (food, medicine, medical devices for sanctioned countries); wind-down licenses (authorizing termination of pre-existing contracts); commercial transaction licenses (for specific goods or services not covered by general licenses); personal remittance licenses; and emergency licenses for time-sensitive transactions. The availability of each license type depends on the specific sanctions program involved — Iran (ITSR), Russia (EO 14024), Cuba (CACR), or others. Dr. Shaun Gregory Morgan has secured 15+ OFAC specific licenses for UAE clients across these programs.
OFAC specific license processing times vary significantly by sanctions program, application complexity, and OFAC's current caseload. Straightforward humanitarian applications may be processed in 60-90 days; complex commercial or Iran-related applications can take 6-18 months. In emergency situations, OFAC does issue expedited authorizations — but these require a compelling case and experienced OFAC license application counsel. An experienced OFAC license application lawyer in Dubai can optimize application quality to minimize processing delays and respond promptly to any OFAC requests for additional information.
A complete OFAC specific license application must include: full identification of all parties to the proposed transaction; a detailed description of the goods, services, or transactions to be authorized; the specific legal authority under which the license is sought; a statement of why the transaction is in the US national interest or otherwise warranted; all relevant supporting documentation; and any prior OFAC correspondence. Applications that are incomplete, insufficiently detailed, or lack legal justification are routinely denied or returned without action — making engaging an expert OFAC license application lawyer in Dubai essential to success.
Yes, OFAC can deny specific license applications that do not meet statutory criteria or policy standards. If an application is denied, the applicant may request administrative reconsideration by submitting additional information or arguments within 30 days of the denial. In some cases, denied applications can be resubmitted with strengthened factual and legal support. An OFAC license application lawyer in Dubai with direct OFAC engagement experience — such as Dr. Shaun Gregory Morgan — can significantly improve the prospects for reconsideration or a successful resubmission.
With 15+ OFAC specific licenses approved for UAE clients across Iran, Russia, Cuba, and other sanctions programs, Dr. Shaun Gregory Morgan is Dubai's leading OFAC license application lawyer. Senior-partner counsel. Direct OFAC engagement. Results that speak for themselves.