So, yesterday OFAC made a number of changes to the Russia program. This first one involves the addition of General License 53 authorizes transactions that are “ordinarily incident and necessary to the official business” for Russia’s diplomatic missions that would normally be prohibited under Directive 4 of Executive Order 14024.
And there is a new related Frequently Asked Question (FAQ):
1096. Do U.S. sanctions prohibit U.S. persons from engaging in transactions that are ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation located in or outside the United States?
OFAC issued Russia-related General License (GL) 53 to authorize U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation (“Russian missions”), where the transactions are prohibited by Directive 4 under Executive Order (E.O.) 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. This authorization applies to transactions related to Russian missions located in or outside the United States. For example, GL 53 authorizes the payment of salaries to employees of Russian missions that may otherwise be prohibited by Directive 4, such as a payment originated by the Ministry of Finance of the Russian Federation from a non-blocked Russian bank. Importantly, GL 53 does not authorize any transactions involving blocked persons, including blocked Russian financial institutions; nor does it authorize debits to the accounts on the books of U.S. financial institutions of entities subject to Directive 4. Non-U.S. persons may engage in transactions that are authorized for U.S. persons under this GL without risk of sanctions under E.O. 14024.
November 10, 2022OFAC Frequently Asked Question 1096
New Frequently Asked Question 1096
Categories: Frequently Asked Questions (FAQ) Guidance Licenses OFAC Updates Russian Harmful Foreign Activities Sanctions
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