Effective as of December of last year, 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 ad conduct of proceedings.

The entire notice of the amendment is available here.