Russian Harmful Foreign Activities Sanctions Program
Treasury’s Russian Harmful Foreign Activities sanctions program is codified at 31 CFR part 587 (Russian Harmful Foreign Activities Sanctions Regulations, or RuHSR).
OFAC has issued many general licenses (GLs) under the Russian Harmful Foreign Activities sanctions authorities to authorize, among other things, humanitarian assistance, agricultural and medical trade, and other support to people impacted by Russia’s further invasion of Ukraine. In all cases, authorized transactions must comply with the terms and conditions set forth in the applicable GL, and the below GLs only authorize activity prohibited by certain authorities.
Agricultural commodities, medicine, and medical devices: Russia-related GL 6A, “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials,” authorizes certain transactions prohibited by the RuHSR that are ordinarily incident and necessary to: (1) the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to, from, or transiting the Russian Federation; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or (3) ongoing clinical trials and other medical research activities that were in effect prior to March 24, 2022.
Telecommunications and internet-based communications: Russia-related GL 25, “Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications,” authorizes certain transactions prohibited by the RuHSR that are ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation, as well as the exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons to the Russian Federation of services, software, hardware, or technology incident to the exchange of communications over the internet, such as instant messaging, videoconferencing, chat and email, social networking, sharing of photos, movies, and documents, web browsing, blogging, web hosting, and domain name registration services.
NGO activities: Russia-related GL 27, “Certain Transactions in Support of Nongovernmental Organizations’ Activities,” authorizes transactions ordinarily incident and necessary to the activities described below by NGOs that are prohibited by the RuHSR, provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to E.O. 14024:
• Activities to support humanitarian projects to meet basic human needs in Ukraine or the Russian Federation, including drought and flood relief; food, nutrition, and medicine distribution; the provision of health services; assistance for vulnerable or displaced populations, including individuals with disabilities and the elderly; and environmental programs;
• Activities to support democracy building in Ukraine or the Russian Federation, including activities to support rule of law, citizen participation, government accountability and transparency, human rights and fundamental freedoms, access to information, and civil society development projects;
• Activities to support education in Ukraine or the Russian Federation, including combating illiteracy, increasing access to education, international exchanges, and assisting education reform projects;
• Activities to support non-commercial development projects directly benefiting the people of Ukraine or the Russian Federation, including related to health, food security, and water and sanitation; and
• Activities to support environmental and natural resource protection in Ukraine or the Russian Federation, including the preservation and protection of threatened or endangered species, responsible and transparent management of natural resources, and the remediation of pollution or other environmental damage.
Personal remittances: Russia-related GL 18, “Authorizing U.S. Dollar-Denominated Banknote Noncommercial, Personal Remittances Prohibited by Executive Order of March 11, 2022,” authorizes certain transactions prohibited by the RuHSR that are ordinarily incident and necessary to the transfer of U.S. dollar-denominated banknote noncommercial, personal remittances from: (i) the United States or a U.S. person, wherever located, to an individual located in the Russian Federation; or (ii) a U.S. person who is an individual located in the Russian Federation.
Personal maintenance of U.S. individuals: Russia-related GL 19, “Authorizing Transactions Related to Personal Maintenance of U.S. Individuals Located in the Russian Federation Prohibited by Executive Order of March 11, 2022,” authorizes individuals who are U.S. persons located in the Russian Federation to engage in certain transactions prohibited by the RuHSR that are ordinarily incident and necessary to their personal maintenance within the Russian Federation, including payment of housing expenses, acquisition of goods or services for personal use, payment of taxes or fees, and purchase or receipt of permits, licenses, or public utility services, subject to certain conditions.
Emergency medical services: Section 587.508 of the RuHSR authorizes the provision and receipt of nonscheduled emergency medical services.
U.S. government business: Section 587.205(b) of the RuHSR exempts transactions that are for the conduct of the official business of the U.S. government.
International organizations: Section 587.205(b) of the RuHSR exempts transactions that are for the conduct of the official business of the United Nations (including its specialized agencies, programs, funds, and related organizations) (UN) by employees, grantees, or contractors thereof. Additional activity related to the UN is also authorized by § 587.510 of the RuHSR. In addition, § 587.510 of the RuHSR authorizes transactions prohibited by the RuHSR that are for the conduct of the official business of the following entities by employees, grantees, or contractors thereof:
o The International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA);
o The African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, and the Inter-American Development Bank Group (IDB Group), including any fund entity administered or established by any of the foregoing; and
o The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies.
Overflight payments, emergency landings, and air ambulance services: Russia-related GL 7, “Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services,” authorizes transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the receipt of, and payment of charges for, services rendered in connection with overflights of the Russian Federation or emergency landings in the Russian Federation by aircraft registered in the United States or owned or controlled by, or chartered to, U.S. persons. GL 7 also authorizes transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to provide air ambulance and related medical services, including medical evacuation, to individuals in the Russian Federation.
• FAQ 978: Guidance on permissible funds transfers involving sanctioned foreign financial institutions.
• FAQ 979: Guidance on transactions for official business of international organizations, certain humanitarian-related trade, or the response to the COVID-19 pandemic.
• FAQ 1025: Guidance on the impact of E.O. 14068 on GL 6.
• FAQ 1028: Guidance on sending noncommercial, personal remittances denominated in U.S. dollars to the Russia Federation.