Ukraine-/Russia-related Sanctions Program
The Ukraine-/Russia-related sanctions program is codified in part at the Ukraine Related Sanctions Regulations, 31 CFR part 589. The Ukraine-/Russia-related sanctions program is a key tool in the U.S. government’s effort to disrupt and deter Russia’s malign activities stemming from Russia’s invasion of Ukraine in 2014 and to impose long-term costs on the Russian government for these activities.
While the Crimea region of Ukraine and the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine are blocked jurisdictions pursuant to E.O.s. 13685 and 14065, respectively, OFAC has issued many GLs under the Ukraine-/Russia- related sanctions program to authorize humanitarian assistance, agricultural and medical trade, and other support to people impacted by Russia’s malign activities. In all cases, authorized transactions must comply with the terms and conditions set forth in the applicable GL and only authorize activity prohibited by certain authorities.
Authorized activities involving the Crimea region of Ukraine: While the Crimea region of Ukraine is comprehensively blocked pursuant to E.O. 13685, OFAC maintains several GLs designed to provide humanitarian relief and assistance to the Ukrainian people, including transactions related to the export of food or medicine, personal remittances, telecommunications, internet services, and mail.
• Agricultural and medical exports: Ukraine-related GL 4, “Authorizing the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Supplies, and Replacement Parts,” authorizes certain transactions prohibited by E.O. 13685 that are ordinarily incident and necessary to: the exportation or reexportation of agricultural commodities, medicine, medical supplies, or replacement parts and components for medical supplies to the Crimea region of Ukraine, or to persons in third countries purchasing specifically for resale to the Crimea region of Ukraine. A list of authorized medical supplies can be found here.
• Personal remittances: Ukraine-related GL 6, “Noncommercial, Personal Remittances Authorized,” authorizes certain transactions prohibited by E.O. 13685 to send and receive, and U.S. depository institutions, U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters are authorized to process transfers of, funds to or from the Crimea region of Ukraine or for or on behalf of an individual ordinarily resident in the Crimea region of Ukraine in cases in which the transfer involves a noncommercial, personal remittance.
• Operation of Accounts: Ukraine-related GL 7, “Operation of Accounts Authorized,” authorizes the operation of an account in a U.S. financial institution for an individual ordinarily resident in the Crimea region of Ukraine other than an individual whose property and interests in property are blocked pursuant to E.O.s 13660, 13661, 13662, or 13685 (collectively, the “Orders”), provided that transactions processed through the account are of a personal nature and not for use in supporting or operating a business; do not involve transfers directly or indirectly to the Crimea region of Ukraine or for the benefit of individuals ordinarily resident in the Crimea region of Ukraine unless authorized by Ukraine-related GL 6 (“Noncommercial, Personal Remittances Authorized”); and are not otherwise prohibited by the Orders.
• Telecommunications and mail: Ukraine-related GL 8, “Transactions Related to Telecommunications and Mail Authorized,” authorizes transactions prohibited by E.O. 13685 with respect to the receipt and transmission of telecommunications involving the Crimea region of Ukraine, as well as certain transactions of common carriers incident to the receipt or transmission of mail and packages between the United States and the Crimea region of Ukraine.
• Internet-based communications: Ukraine-related GL 9, “Exportation of Certain Services and Software Incident to Internet-Based Communications Authorized,” authorizes, as otherwise prohibited by E.O. 13685, the exportation or reexportation, directly or indirectly, from the United States or by U.S. persons, wherever located, to persons in the Crimea region of Ukraine, of certain services incident to the exchange of personal communications over the internet, such as instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, and blogging, as well as the export of software to enable such services. Ukraine-related GL 9 also authorizes the exportation or reexportation, directly or indirectly, from the United States or by U.S. persons, wherever located, to persons in the Crimea region of Ukraine of software necessary to enable the certain services.
• Journalistic activities and establishment of news bureaus: Ukraine-related GL 25, “Journalistic Activities and Establishment of News Bureaus in Certain Regions of Ukraine,” authorizes news reporting organizations that are U.S. persons and individuals who are U.S. persons regularly employed by a news reporting organization, either as journalists (including photojournalists) or as supporting broadcast or technical personnel, to engage in the certain transactions in the Crimea region of Ukraine, that are ordinarily incident and necessary to their journalistic activities in said region (see below for details on how this GL also applies to the DNR and LNR regions of Ukraine).
o FAQ 453: Guidance on sending noncommercial, personal remittances to or from the Crimea region of Ukraine.
o FAQ 454: Guidance on the export or reexport services or software with knowledge or reason to know that such services or software are intended for an individual or entity identified on the Sectoral Sanctions Identification List.