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OFAC updates 2 Russia GLs, issues 2 more, and makes FAQ updates

Issuance of Russia-related General Licenses; Publication of new and amended Russia-related Frequently Asked Questions

05/05/2022

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 7A, General License 26A, General License 31, and General License 32. In addition, OFAC has published one new Frequently Asked Question and amended one Frequently Asked Question.

General License 7A makes some tweaks to GL7, including disallowing debits to accounts of the National Wealth Fund, the Central Bank and Ministry of Finance. General License 26A adds Sberbank (Switzerland) AG. General License 31 authorizes transactions for patents, trademarks and copyrights. And General License 32 authorizes wind down transactions involving Amsterdam Trade Bank.

There’s one new:

AFGHANISTAN-RELATED SANCTIONS

1032. On April 20, 2022, Transkapitalbank (TKB) was designated pursuant to Russia-related Executive Order 14024.  Can U.S. persons continue to engage in Afghanistan-related transactions with TKB?

Answer

Yes.  The Office of Foreign Assets Control (OFAC) issued two general licenses (GLs)related to TKB, which allow U.S. persons to engage in certain transactions involving TKB for specified time periods.

Russia-related GL 28 authorizes U.S. persons to engage in certain transactions involving TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, that are ultimately destined for or originating from Afghanistan through 12:01 a.m. eastern daylight time, October 20, 2022. 

GL 28 also authorizes U.S. financial institutions to operate correspondent accounts on behalf of TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, provided such accounts are used solely to effect transactions ultimately destined for or originating from Afghanistan that are authorized by the GL.  This means that U.S. financial institutions are authorized to debit or credit correspondent accounts maintained for TKB, provided these debits or credits are for payments that are ultimately destined for or originating from Afghanistan.

In addition, through 12:01 a.m. eastern daylight time, May 20, 2022, Russia-related GL 29 authorizes certain transactions ordinarily incident and necessary to the wind down of transactions involving TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, regardless of whether such transactions are related to Afghanistan.  GL 29 does not authorize debits to blocked accounts.  For more information, please see FAQ 990.

For further information on relevant authorizations, exemptions, and public guidance, please review OFAC’s Fact Sheets, “Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine” and “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People.”

and one amended:


1009. Does Executive Order (E.O.) 14065 block the entire Donetsk and Luhansk oblasts?

Answer

No.  E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic 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”).  In determining whether a location is within the regions subject to sanctions, U.S. persons may reasonably rely on vetted information from reliable third parties, such as postal codes and maps.

U.S. persons engaging in activity that does not involve the Covered Regions are not subject to the prohibitions in E.O. 14065. Please see FAQ 1006 for what prohibitions apply to the Covered Regions.

Frequently Asked Question (FAQ).

Links:

OFAC Notice

Updated GLs: 7A, 26A

New GLs: 31, 32

New FAQ

Amended FAQ

Categories: Frequently Asked Questions (FAQ) Licenses OFAC Updates Russian Harmful Foreign Activities Sanctions Wind Down Activities

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