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March 24, 2022: The more things change… more Russia General Licenses, and amended FAQs

On Thursday, OFAC issued new versions of Russia-related General License 6 & 17, and a new one (20), as well as a new Ukraine-/Russia-related General License. Most of the changes to GL 6 are fairly administrative (e.g. adding references to Executive Order numbers and the recently released Russian Harmful Foreign Activities Regulations), but it notably makes an additional carve-out for clinical trials. GL 17A leaves the deadline for transactions related to non-industrial diamonds and alcoholic beverages intact (it’s today), but extends the one for fish & seafood till June 22nd.

GL 20 is new, and authorizes 3rd country diplomatic and consiular funds transfers. And Ukraine-/Russia-related GL 25 authorizes transactions for journalism activities and establishing news bureaus in specified areas of Ukraine (basically, the Russian-controlled areas).

In addition, they updated the following 2 Frequently Asked Questions (FAQs) – however, at the time I write this, the link to these is broken.


Russia-related General Licenses 6A, 17A, 20

Ukraine-.Russia-related General License 25

Categories: Frequently Asked Questions (FAQ) Guidance Licenses OFAC Updates Russian Harmful Foreign Activities Sanctions Ukraine sanctions


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