Yesterday, OFAC issued its first General License for the cyber-related sanctions program, authorizing certain transactions with Russia’s Federal Security Service, or FSB. Which transactions? Those “that are necessary and ordinarily incident to requesting certain licenses and authorizations for the importation, distribution, or use of certain information technology products in the Russian Federation, as well as transactions necessary and ordinarily incident to comply with rules and regulations administered by, and certain actions or investigations involving, the FSB.”
What’s excluded? Exports to Crimea or anything actually benefitting the FSB.