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Russia-related General License 24 plus an amended FAQ from OFAC (UPDATED)

The new General License is for maritime services:

Transactions Related to the Provision of Maritime Services

(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by Executive Order (E.O.) 14065 related to the provision or receipt of civil maritime services performed by individuals who are ordinarily resident in the so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine, or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”), are authorized, provided that:

(1) Such services are performed outside the Covered Regions; and

(2) Such services are not performed on behalf of any entity located in, or organized under the laws of, the Covered Regions.

(b) This general license does not authorize:

(1) Any new investment in the Covered Regions prohibited by E.O. 14065, unless separately authorized; or

(2) Any transactions involving any person blocked pursuant to E.O. 14065, unless separately authorized.

And Frequently Asked Question 1020 was amended:

1,020. Does Executive Order (E.O.) 14066 prohibit dealing in Kazakh-origin crude oil of the Caspian Pipeline Consortium (“CPC”)?

No. The importation prohibition of E.O. 14066 applies to the import of certain products of Russian Federation origin to the United States and excludes imports that are not of Russian Federation origin, even if such items transit through or depart from the Russian Federation. The CPC transports crude oil through the CPC pipeline that is predominantly of Kazakh origin and that is marketed and loaded with a certificate of origin verifying that the crude is of Kazakh origin. Any crude oil that is primarily of Russian Federation origin is marketed and loaded separately and certified as Russian origin. For purposes of assessing whether crude oil marketed by the CPC is of Russian origin, U.S. persons may reasonably rely upon a certificate of origin, but should exercise caution if they have a reason to believe such certificate has been falsified.

UPDATE: The General License is under the Ukraine/Russia-related program, not the Russian Harmful Foreign Activities program. OFAC’s terminology is not consistent in this regard – designations under E.O. 14024 are labeled “Russia-related”, too.

Links:

OFAC Notice

General License 24

Amended FAQ

Categories: Frequently Asked Questions (FAQ) Licenses OFAC Updates Ukraine sanctions

eric9to5

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