Sanctions Developments Resulting From the Conflict in Ukraine - United States

Table of Contents:

• Summary
• Economic Sanctions
• General Licenses
• Export Controls

1. Summary

   In response to the ongoing military conflict in Ukraine that began in February 2022, the United States has adopted various economic sanctions and trade and investment restrictions.  Those measures, which are summarized and described in further detail below, are in addition to measures that were in place prior to February 2022 (those pre-existing measures are not addressed below).  This summary is current as of March 6, 2024.[1]

   2. Economic Sanctions

   2.1. Donetsk and Luhansk Territorial Sanctions

   Executive Order 14065 (“Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”), issued on February 21, 2022, imposes sanctions on the so-called Donetsk People’s Republic (“DNR”), the so-called Luhansk People’s Republic (“LNR”) and any other regions of Ukraine as may be determined by the Secretary of the Treasury (collectively, the “Covered Regions”).[2]

   • Territorial Sanctions.  Executive Order 14065 effectively extends existing U.S. comprehensive sanctions against the Crimea region of Ukraine to the Covered Regions by prohibiting U.S. persons from dealing with, in or relating to the Covered Regions, including:  (i) new investment in the Covered Regions, (ii) the importation into the United States of any goods, services or technology from the Covered Regions, (iii) the exportation, reexportation, sale or supply of any goods, services or technology from the United States to the Covered Regions, and (iv) any approval, financing, facilitation or guarantee of such prohibited dealings.
     • OFAC has issued guidance stating that Executive Order 14065 targets only the DNR, LNR and other Covered Regions determined by the Secretary of the Treasury, and not the entire Donetsk and Luhansk oblasts.[3]  The disputed Kherson and Zaporizhzhia regions have not been sanctioned by the United States.
     • Executive Order 14065 also includes standard language prohibiting transactions that evade or avoid, have the purpose of evading or avoiding, cause violations of or attempt to violate the other prohibitions described in Executive Order 14065.

   2.2. Blocking Sanctions

   Since February 21, 2022, OFAC has designated a significant number of Russian persons and entities as “specially designated nationals” (“SDNs”) subject to blocking sanctions.  U.S. persons generally are prohibited from engaging in any transactions or other dealings with or involving parties subject to blocking sanctions.  Additionally, U.S. persons are required to block the property and interests in property of SDNs in their possession or control and report such blocked property to OFAC.  These blocking sanctions generally also apply to any entity owned 50% or more by an SDN (or multiple SDNs).  OFAC has made these SDN designations pursuant to a variety of Russia-related Executive Orders and other authorizations, but most of the designations have been made pursuant to Executive Order 14024 (“Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation”), a pre-existing Russia-related Executive Order dated April 19, 2021.[4]

   Subsequent sectoral determinations issued pursuant to Executive Order 14024 authorize blocking sanctions against persons determined to operate in the following sectors of the Russian economy: technology; [5] defense or related materiel;[6] financial services;[7] aerospace; electronics; marine;[8] accounting; trust and corporate formation; management consulting;[9] quantum computing;[10] metals and mining;[11] architecture; engineering; construction; manufacturing; and transportation.[12]

   Executive Order 14065[13] also authorizes the imposition of blocking sanctions on any person determined to:  (1) operate or have operated in the Covered Regions after February 21, 2022, (2) be a leader, official, senior executive officer or member of the board of directors of an entity operating in the Covered Regions after February 21, 2022, (3) be owned or controlled by, or to have acted or purported to act for or on behalf of a person designated for blocking sanctions under Executive Order 14065, and (4) have materially assisted, sponsored or provided financial, material or technological support for, or goods or services to or in support of, a person designated for blocking sanctions under Executive Order 14065.

   A significant number of entities and individuals have been designated by OFAC as SDNs subject to blocking sanctions, including major Russian financial institutions;[14] certain major Russian aerospace, electronics and marine companies;[15] The Russian Direct Investment Fund (“RDIF”) and related entities;[16] certain Russian defense companies;[17] certain technology and defense firms that provide services or produce various technological products for the Russian Ministry of Defense;[18] Nord Stream 2 AG, the company behind the Nord Stream 2 pipeline;[19] and Russian President Putin (and members of his family), Russian Minister of Foreign Affairs Sergei Viktorovich Lavrov, senior Russian military officials Valery Gerasimov and Sergei Shoigu and elites, so-called “oligarchs,” and political and national security leaders with close ties to Russian President Putin;[20] and parties determined to be facilitating Russia’s aggression in Ukraine.[21]

   The United States has also, citing Belarus’s support for, and facilitation of, Russian military activity in Ukraine, designated  Belarusian individuals and entities, active in the Belarusian defense and security sectors as SDNs subject to blocking sanctions.[22]  Belarusian President Alexandr Lukashenko and various members of his family have also been designated or re-designated, as applicable, as SDNs subject to blocking sanctions for corruption-related conduct not specifically connected to the conflict in Ukraine.[23]

   2.3. Secondary Sanctions and Designation Authorities

   The entities and individuals referenced above have been designated under one or more OFAC designation authorities issued after February 2022.  In addition, on December 22, 2023, the Biden administration issued Executive Order 14114, which authorized the imposition of secondary sanctions[24] on foreign financial institutions determined by the U.S. government to have conducted or facilitated any “significant” transaction or transactions:

   • for or on behalf of parties sanctioned under E.O. 14114 for operating or having operated in the technology, defense and related materiel, construction, aerospace, or manufacturing sectors of the Russian economy (or other such sectors as may be determined by the U.S. government to support Russia’s military-industrial base);[25] or
   • or provided any service involving Russia’s military-industrial base, including the sale, supply or transfer, directly or indirectly, to Russia of any critical item or class of items as may be determined by the U.S. government.

   The targeted transactions and services may include maintaining accounts, transferring funds, or providing other financial services (i.e., payment processing, trade finance, insurance) for any persons designated for operating in the specified sectors or for any persons, either inside or outside Russia, that support Russian’s military-industrial base.[26]  Additionally, the list of critical items[27] that support Russia’s military-industrial base includes certain machine tools and manufacturing equipment, manufacturing materials for semiconductors and related electronics, electronic test equipment, propellants, chemical precursors for propellants and explosives, lubricants and lubricant additives, bearings, advanced optical systems, and navigation instruments. With respect to the FFIs determined to engage in the aforementioned activities, the U.S. government is authorized to (1) prohibit the opening of, or prohibit or impose strict conditions on the maintenance of, correspondent accounts or payable-through accounts in the United States for such FFIs, or (2) impose blocking sanctions on such FFIs (i.e., designation of such FFIs on the list of “SDNs” maintained by OFAC.

   2.4. Non-Blocking Sanctions

   In addition to the above-described SDN designations, the United States has adopted the following non-blocking sanctions that prohibit or restrict certain dealings and transactions in certain sectors or with certain Russian parties.

   2.4.1. Russian Sovereign Debt Restrictions

   Russia-related Directive 1A Under Executive Order 14024 (“Prohibitions Related to Certain Sovereign Debt of the Russian Federation”), issued on February 23, 2022, expands existing U.S. restrictions on dealings by U.S. financial institutions in Russian sovereign debt (described in our earlier blog post[28]) to prohibit U.S. financial institutions from participating in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Russian Central Bank, the Russian Ministry of Finance or the Russian National Wealth Fund.[29]  Directive 1A further updates the definition of “U.S. financial institutions” to include money services businesses, operators of credit card systems, insurance companies and dealers in precious metals, stones or jewels.  OFAC has issued guidance stating that the 50 Percent Rule[30] does not apply to Directive 1A.[31]

   2.4.2. Correspondent or Payable-Through Accounts Restrictions

   Russia-related Directive 2 Under Executive Order 14024 (“Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions”), issued on February 24, 2022, prohibits, beginning on March 26, 2022, “U.S. financial institutions”[32] from opening or maintaining correspondent accounts or payable-through accounts for or on behalf of, or processing transactions involving, certain foreign financial institutions designated in the Annex to Directive 2, which currently is limited to Sberbank and 24 Sberbank subsidiaries and/or affiliates.[33]  Although OFAC issued guidance stating that the 50 Percent Rule does apply to Directive 2,[34] because Sberbank and its subsidiaries have now been listed on the SDN list, this directive is essentially moot.

   2.4.3. Debt and Equity Restrictions

   Russia-related Directive 3 Under Executive Order 14024, (“Prohibitions Related to New Debt and Equity of Certain Russia-related Entities”), issued on February 24, 2022, prohibits transactions in, provision of financing for and other dealings involving U.S. persons or within U.S. jurisdiction in new debt with longer than a 14-day maturity or new equity issued after 12:01 AM EST on March 26, 2022 by certain major corporate entities and financial institutions designated in the Annex to Directive 3.[35]  OFAC has issued guidance stating that the 50 Percent Rule does apply to Directive 3.[36]

   2.4.4. Restrictions on Dealings with Russian State Financial Institutions

   Russia-related Directive 4 Under Executive Order 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”), issued on February 28, 2022, and amended on May 19, 2023, prohibits U.S. persons from engaging in any transaction, direct or indirect,[37] involving the Russian Central Bank, the Russian Ministry of Finance or the Russian National Wealth Fund, including any transfer of assets to such entities and any foreign exchange transaction for or on behalf of such entities.[38]  Related measures have also been implemented by the European Union and the United Kingdom.  Directive 4 has led to challenges for parties that pursue divestments requiring the payment of an exit tax in Russia, as the payment of this tax could potentially require transactions involving the Central Bank of Russia or Russia’s Ministry of Finance.  Consequently, OFAC released guidance noting that U.S. persons whose divestment of assets in Russia involve a payment of an exit tax require a specific license from OFAC prior to the payment of the tax.[39]  Although similar to blocking sanctions in some respects in that U.S. persons generally are prohibited from engaging in transactions with the designated entities, the designations of the Russian Central Bank, the Russian Ministry of Finance and the Russian National Wealth Fund under Directive 4 do not require U.S. persons to block the property of, or property in which an interest is held by, the Russian Central Bank, the Russian Ministry of Finance and the Russian National Wealth Fund that comes within their possession or control or within the United States.[40]

   • OFAC has issued guidance clarifying that (1) the 50 Percent Rule does not apply to Directive 4,[41] and (2) Directive 4 does not prohibit trading in the secondary markets for debt or equity issued by the Russian Central Bank, the Russian Ministry of Finance or the Russian National Wealth Fund so long as none of the Russian Central Bank, the Russian Ministry of Finance or the Russian National Wealth Fund is a counterparty to such transactions and subject to the restrictions on U.S. financial institutions in Russia-related Directive 1A.[42]
   • As described below, OFAC has issued revised Russia-related GL-8H, which adds the Russian Central Bank (but not RDIF, the Russian Ministry of Finance or the Russian National Wealth Fund) to the list of entities with which otherwise prohibited transactions “related to energy” may be conducted.[43]

   2.4.5. Importation,  Investment, and Services Restrictions

   Executive Order 14066 (“Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”), issued on March 8, 2022, prohibits (1) the importation of certain Russian Federation-origin energy/oil products (including crude oil, petroleum, petroleum fuels, oils and products of their distillation, liquefied natural gas, coal and coal products) into the United States, and (2) new investment by U.S. persons, wherever located, in the energy sector in the Russian Federation.[44]  OFAC guidance provides that “new investment in the energy sector” means a commitment or contribution of funds or other assets for, or a loan or other extension of credit to, new energy sector activities (excluding maintenance or repair) located or occurring in the Russian Federation on or after March 8, 2022.[45]

   Executive Order 14068 (“Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression”), issued on March 11, 2022, and amended by Executive Order 14114 issued on December 22, 2023, prohibits (1) the importation and entry into the United States, including importation for admission into a foreign trade zone located in the United States, of Russian Federation-origin fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds, (2) the exportation, reexportation, sale, or supply, directly or indirectly, of luxury goods from the United States or by a U.S. person, wherever located, to any person located in the Russian Federation, and (3) the exportation, reexportation, sale, or supply, directly or indirectly, of U.S. dollar-denominated banknotes from the United States or by a U.S. person, wherever located, to the Russian government or any person located in the Russian Federation.[46]  Additionally, Executive Order 14068 authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to prohibit new investments in sectors of the Russian economy (as discussed above, new investments in the energy sector are already prohibited).

   The Executive Order also provides relevant U.S. government agencies with the authority to impose import and export restrictions on additional products and items. For example, on June 18, 2022, OFAC issued a determination expanding the scope of Executive Order 14068 to prohibit the importation into the United States of gold of Russian Federation origin.[47]  On December 22, 2023, OFAC issued another determination[48] that expands the scope of Executive Order 14068 to prohibit the importation fish and seafood (specifically, salmon, cod, pollock, and crab) that were produced wholly or in part in Russia, or harvested in waters under the jurisdiction of Russia or by Russia-flagged vessels, notwithstanding whether such fish, seafood, and preparations thereof had been incorporated or substantially transformed into another product outside of Russia.  On February 8, 2024 OFAC issued an additional determination that prohibited the importation of certain diamonds that were mined, extracted, produced, or manufactured wholly or in part in Russia, notwithstanding whether such diamonds had been substantially transformed into other products outside of Russia.[49]

   Executive Order 14071 (“Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression”), issued on April 6, 2022, prohibits (1) new investments in the Russian Federation by U.S. persons, (2) the exportation, reexportation, sale or supply, directly or indirectly, of any category of services as may be determined by the Secretary of the Treasury from the United States or by U.S. persons to any person located in the Russian Federation, and (3) any approval, financing, facilitation or guarantee by U.S. persons of transactions conducted by foreign persons that would be prohibited by (1) or (2) if performed by U.S. persons or within the United States.[50]

   • OFAC has issued several determinations pursuant to Section 1(a)(ii) of Executive Order 14071 that define the categories of services subject to the exportation of services ban. Pursuant to those determinations, the exportation ban applies to the following categories: accounting services; trust and corporate formation services; management consulting services;[51] quantum computing services;[52] architecture and engineering services.[53]
   • Crude Oil and Petroleum Price Cap. In addition to the categories of services outlined above, OFAC has also issued determinations pursuant to Section 1(a)(ii) of Executive Order 14071 imposing a price cap on Russian-origin crude oil and petroleum products by establishing a services ban that applies when such crude oil or petroleum products is sold above a certain price. The services covered by the U.S. maritime services ban include:  (1) trading/commodities brokering, (2) financing, (3) shipping, (4) insurance, including reinsurance and protection and indemnity, (5) flagging, and (6) customs brokering, as such services relate to maritime transport of petroleum products of Russian Federation origin.  Since February 5, 2023, the price cap on Discount to Crude[54] petroleum products of Russian Federation origin is $45 per barrel, and the price cap on Premium to Crude[55] petroleum products is $100 per barrel.[56] The price cap for crude oil is $60 per barrel.[57]
   • OFAC has issued guidance regarding the scope and application of the new investment ban.  Among other things, OFAC has clarified that:
     • It views “new investment” as “the commitment of capital or other assets for the purpose of generating returns or appreciation” made on or after April 6, 2022.  The wind down or divestment of a pre-existing investment is not prohibited by the new investment ban.[58]
     • “New investment” does not include the “maintenance” of pre-existing investments, projects, or operations in Russia.  Maintenance includes all transactions ordinarily incident to performing under an agreement in effect prior to April 6, 2022, provided that such transactions are consistent with previously established practices and support (but do not expand) pre-existing projects or operations in Russia.[59]
     • The new investment ban prohibits U.S. persons from purchasing both new and existing debt and equity securities issued by an entity in Russia, but does not prohibit U.S. persons from selling or divesting debt or equity securities issued by an entity in Russia to a non-U.S. person.[60]
     • The new investment ban does not prohibit U.S. persons from lending funds to, or purchasing an equity interest in, entities located outside of Russia so long as (1) the funds used for such transactions are not specifically intended for new projects or operations in Russia, and (2) the entity located outside Russia derives less than 50 percent of its revenues from its investments in Russia.[61]

   2.5. Additional OFAC Guidance

   Since February 21, 2022, OFAC has issued various guidance relating to the above-described blocking and non-blocking sanctions in the form of new Frequently Asked Questions (“FAQs”) and amended FAQs.  OFAC’s FAQs are available here.[62]

   3. General Licenses[63]

   3.1. Ukraine-Related GLs

   In connection with the above-described territorial sanctions on the DNR and LNR, OFAC has issued the following active Ukraine GLs (some of which are similar to the GLs that OFAC has issued in connection with other comprehensive sanctions programs) permitting certain otherwise prohibited transactions:

   • Ukraine GL-18:  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 the Covered Regions, or (2) the prevention, diagnosis or treatment of COVID-19 (including research or clinical studies) in the Covered Regions;[64]
   • Ukraine GL-19:  ordinarily incident and necessary to the receipt or transmission of telecommunications (but not the provision, sale or lease of telecommunications equipment or technology or capacity on telecommunications transmission facilities) involving the Covered Regions;[65]
   • Ukraine GL-20:  for the official business ofcertain international organizations and entities, including conduct by employees, grantees or contractors;[66]
   • Ukraine GL-21:  ordinarily incident and necessary to (1) noncommercial, personal remittances (charitable donations or funds to benefit entities or in support of businesses (including family-owned businesses) are expressly excluded), or (2) maintaining, operating or closing an account for individuals ordinarily resident in the Covered Regions (as long as the person is not designated for blocking sanctions pursuant to Executive Order 14065), provided that the transactions processed through the account are noncommercial, personal remittances that are of a personal nature and not for the benefit of an entity, including supporting or operating a business;[67]
   • Ukraine GL-22:  the exportation or reexportation to persons in the Covered Regions ofcertainservices incident to the exchange of personal internet-based communications (including instant messaging, chat and email, social networking, sharing of photos and movies, web browsing and blogging) or software necessary to enable such services (provided that the software satisfies certain criteria);[68]
   • Ukraine GL-23:  ordinarily incident and necessary to certain humanitarian, democracy building, educational, noncommercial development, and environmental activities by nongovernmental organizations, including the processing and transfer of funds, payment of taxes, fees, and import duties, and purchase or receipt of permits, licenses, or public utility services.[69]  Note that GL-23 was issued on March 11, 2022, while GLs 19-22 were issued on February 21, 2022;
   • Ukraine GL-24:  the provision or receipt of civil maritime services performed by individuals ordinarily resident in the Covered Regions so long as the services are performed outside the Covered Regions and the services are not performed on behalf of any entity located or organized in the Covered Regions, and an amended FAQ;[70]
   • Ukraine GL-25:  ordinarily incident and necessary in the Covered Regions by U.S. news organizations and U.S. journalists and related personnel to support their journalistic activities (including, for example, hiring and paying support staff, leasing office space and purchasing necessary goods and services).[71]

   3.2. Russia-Related GLs

   In connection with the above-described blocking and non-blocking sanctions, OFAC has issued several Russia-related GLs since February 2022 permitting certain otherwise prohibited transactions:

   • Russia-related GL-1A:  involving Federal State Budgetary Institution Marine Rescue Service (MRS), or any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest, that are not related to the construction of the Nord Stream 2 pipeline project, the TurkStream pipeline project, or any project that is a successor to either such project, as long as such transactions (1) do not involve any vessels identified on OFAC’s SDN List as blocked property of MRS, including vessels identified as blocked property of any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest; or (2) are not prohibited by Executive Order of August 20, 2021 or PEESA, or any part of 31 CFR chapter V, other statute, or other Executive order, or involving any blocked person other than the blocked persons identified in this general license[72];[73]
   • Russia-related GL-2:  ordinarily incident and necessary to the servicing of bonds issued before March 1, 2022 by the Russian Central Bank, National Wealth Fund or Ministry of Finance (that are not otherwise prohibited under Directive 1A);[74]
   • Russia-related GL-6C:  related to (1) the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices or software updates for medical devices, (2) the prevention, diagnosis or treatment of COVID-19 (including research or clinical studies), or (3) ongoing clinical trials and other medical research activities[75];[76]
   • Russia-related GL-7A:  ordinarily incident and necessary to (1) the receipt of, and payment of charges for, services rendered in connection with overflights of Russia or emergency landings in Russia by aircraft registered in the United States or owned or controlled by, or chartered to, U.S. persons, and (2) air ambulance and related medical services, including medical evacuation, to individuals in Russia, so long as such transactions are not prohibited by Directive 2 under Executive Order 14024 and do not involve any debit to an account on the books of a U.S. financial institution of the Russian Central Bank, Russian Ministry of Finance or Russian National Wealth Fund[77];[78]
   • Russia-related GL-8H:  with VEB, Otkritie, Sovcombank, Sberbank, VTB Bank, Alfa-Bank[79] or their majority-owned subsidiaries or the Russian Central Bank[80] “related to energy,” so long as the transactions do not involve the opening or maintaining of a correspondent account or payable-through account for or on behalf of the entities listed in the Annex to the above-referenced Directive 2 or involve any other persons blocked pursuant to Executive Order 14024[81];[82]
   • Russia-related GL-13H:  to pay taxes, fees or import duties, and purchase or receive permits, licenses, registrations, certifications, or tax refunds provided such transactions are ordinarily incident and necessary to such U.S. persons’ day-to-day operations in Russia (to the extent such transactions are prohibited by Russia-related Directive 4) until 12:01 AM EST on April 17, 2024, so long as such transactions do not involve any debit to an account on the books of a U.S. financial institution of the Central Bank of the Russian Federation, or the Ministry of Finance of the Russian Federation, or are not otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), including transactions involving any persons blocked pursuant to RuHSR (unless separately authorized);[83]
   • Russia-related GL-14:  involving the Russian Central Bank, the Russian Ministry of Finance or the Russian National Wealth Fund’s where their sole function is to act as an operator of a clearing and settlement system, so long as (1) there is no transfer of assets to or from the Russian Central Bank, the Russian Ministry of Finance or the Russian National Wealth Fund, unless separately authorized, and (2) none of the Russian Central Bank, the Russian Ministry of Finance and the Russian National Wealth Fund is either a counterparty or a beneficiary of the transaction, unless separately authorized; [84]
   • Russia-related GL-18:  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;[85]
   • Russia-related GL-19:  ordinarily incident and necessary to personal maintenance by individuals who are U.S. persons located in 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;[86]
   • Russia-related GL-20:  ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in the Russian Federation;[87]
   • Russia-related GL-25C:  (1) ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation, and (2) the exportation or reexportation, sale or supply, directly or indirectly, from the United States or by U.S. person, wherever located, 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) to the Russian Federation, so long as such transactions do not involve the opening or maintaining of a correspondent account or payable-through account for or on behalf of any entity subject to the above-referenced Directive 2 under Executive Order 14024, do not involve any debit to an account on the books of a U.S. financial institution of the Russian Central Bank, Russian Ministry of Finance or Russian National Wealth Fund, are not otherwise prohibited by Executive Orders 14066 or 14068, or involve Channel One Russia, NTV Broadcasting Company, Television Station Russia-1, Algoritm, New Eastern Outlook, or Oriental Review (unless separately authorized)[88];[89]
   • Russia-related GL-27:  ordinarily incident and necessary to certain activities of nongovernmental organizations (activities to support humanitarian projects to meet basic human needs, democracy, education, non-commercial development projects, and environmental and natural resource protection in Ukraine or Russia), so long as such transactions are not prohibited by Directive 2 under Executive Order 14024, do not involve any debit to an account on the books of a U.S. financial institution of the Russian Central Bank, Russian Ministry of Finance or Russian National Wealth Fund, or are not otherwise prohibited by Executive Orders 14066 or 14068;[90]
   • Russia-related GL-31:  certain transactions in connection with a patent, trademark, copyright, or other form of intellectual property protection in the United States or Russia, so long as such transactions are not prohibited by Directive 2 under Executive Order 14024, do not involve any debit to an account on the books of a U.S. financial institution of the Russian Central Bank, Russian Ministry of Finance or Russian National Wealth Fund, or are not otherwise prohibited by Executive Orders 14066 or 14068;[91]
   • Russia-related GL-38A:  ordinarily incident and necessary to the processing of pension payments to (1) U.S. persons or (2) non-U.S. persons not located in Russia (provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to Executive Order 14024), so long as such transactions do not involve the opening or maintaining of a correspondent account or payable-through account for or on behalf of any entity subject to Directive 2 under Executive Order 14024, do not involve any debit to an account on the books of a U.S. financial institution of the Russian Central Bank, Russian National Wealth Fund, or the Russian Ministry of Finance, or any transactions prohibited by RuHSR, including transactions involving any persons blocked pursuant to RuHSR (but excluding transactions with the blocked persons described in this license, unless separately authorized);[92];[93]
   • Russia-related GL-40C:  ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving one or more blocked entities identified in the Annex to Russia-related GL-40C, provided that (1) the aircraft is registered in a jurisdiction solely outside of Russia and (2) the goods, technology, or services that are provided, exported, or reexported are for use on aircraft operated solely for civil aviation purposes, so long as such transactions are not otherwise prohibited by Directive 2 and Directive 4 of Executive Order 14024 or by RuHSR, including transactions involving any person blocked pursuant to the RuHSR, (but excluding transactions with the blocked entities identified in the Annex to Russia-related GL-40C);[94]
   • Russia-related GL-42:  (1) involving the Federal Security Service, provided that such transactions and activities are ordinarily incident and necessary to (i) requesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or notifications issued or registered by the Federal Security Service for the importation, distribution, or use of information technology products in Russia, provided that (a) the exportation, reexportation, or provision of any goods or technology that are subject to the Export Administration Regulations is licensed or otherwise authorized by the Department of Commerce, and (b) the payment of any fees to the Federal Security Service for such licenses, permits, certifications, or notifications does not exceed $5,000 in any calendar year;[95] (ii) complying with law enforcement or administrative actions or investigations involving the Federal Security Service; and (iii) complying with rules and regulations administered by the Federal Security Service, as long as all such transactions are not otherwise prohibited by Directive 2 under Executive Order 14024, Directive 4 under Executive Order 14024, or RuHSR, including transactions involving any person blocked pursuant to RuHSR (but excluding transactions with the blocked person described in Section 1 of this Russia-related General License)[96];[97]
   • Russia-related GL-44:  ordinarily incident and necessary to the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of tax preparation or filing services to any individual who is a U.S. person located in Russia, so long as such transactions are not otherwise prohibited by RuHSR;[98]
   • Russia-related GL-46:  (1) related to the establishment, administration, participation in, and execution of an auction process as announced by the EMEA Credit Derivatives Determination Committee to settle credit derivative transactions with a reference entity of the Russian Federation, (2) the purchase or receipt of debt obligations of the Russian Federation by U.S. persons in certain time periods around such an auction, and (3) ordinarily incident and necessary to facilitating, clearing, and settling transactions authorized by Russia-related GL-46, so long as such transactions are not otherwise prohibited by RuHSR;[99]
   • Russia-related GL-50:  ordinarily incident and necessary to (i) the closing of an account of an individual, wherever located, who is not a blocked person, held at a financial institution blocked pursuant to E.O. 14024, and (ii) the unblocking and lump sum transfer of all remaining funds and other assets in the account to the account holder, including to an account of the account holder held at a non-blocked financial institution, as long as such transactions (1) do not open or maintain a correspondent account or payable-through account for or on behalf of any entity subject to Directive 2 under Executive Order 14024, (2) are otherwise prohibited by Directive 4 under Executive Order 14024, or (3) are otherwise prohibited under RuHSR, including transactions involving any person blocked pursuant to RuSHR (but excluding transactions with blocked persons described in Russia-related General License No. 50, or unless separately authorized);[100]
   • Russia-related GL-52:  ordinarily incident and necessary to journalistic activities or to the establishment or operation of a news bureau for news reporting organizations[101] that are U.S. persons, and individual U.S. persons who are journalists (including photojournalists) or broadcast or technical personnel, provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to Executive Order 14024; authorized transactions include: (1) compensating support staff (e.g., stringers, translators, interpreters, camera operators, technical experts, freelance producers, or drivers), persons to handle logistics, or other office personnel, (2) leasing or renting office space, (3) purchasing, leasing, or renting goods and services (e.g., mobile phones and related airtime), and (4) paying for all other expenses ordinarily incident and necessary to journalistic activities, including sales or employment taxes, as long as such transactions do not open or maintain a correspondent account or payable-through account for or on behalf of any entity subject to Directive 2 under Executive Order 14024; do not debit an account on the books of a U.S. financial institution of the Central Bank of Russia, the National Wealth Fund of Russia, or the Russian Ministry of Finance; do not involve: Joint Stock Company Channel One Russia, Joint Stock Company NTV Broadcasting Company, Television Station Russia-1, Limited Liability Company Algoritm, New Eastern Outlook, or Oriental Review, unless separately authorized; or are not otherwise prohibited by RuHSR, including transactions involving any person blocked pursuant to RuSHR (but excluding transactions with blocked persons described in Russia-related General License No. 52, or unless separately authorized);[102]
   • Russia-related GL-53:  ordinarily incident and necessary to official business of diplomatic or consular missions of the Government of the Russian Federation; authorized transactions include compensating employees of Russian missions, including payment of salaries and reimbursement of expenses;[103]
   • Russia-related GL-54A:  ordinarily incident and necessary to the purchase or receipt of any debt or equity securities of VEON Ltd. or VEON Holdings B.V., but only if the debt or equity securities were issued prior to June 6, 2022;[104]
   • Russia-related GL-55A:  related to the maritime transport of crude oil originating from the Sakhalin-2 project (“Sakhalin-2 byproduct”) through 12:01 a.m. eastern daylight time, June 28, 2024, provided that the Sakalin-2 byproduct is solely for importation into Japan[105];[106]
   • Russia-related GL-56A:  related to the importation of crude oil or other petroleum products into the Republic of Bulgaria, the Republic of Croatia, or other landlocked European Union Member States as described in Council Regulation (EU) 2022/879 of June 3, 2022;[107]
   • Russia-related GL-57A:  ordinarily incident and necessary to addressing vessel emergencies related to the health or safety of the crew or environmental protection, including safe docking or anchoring, emergency repairs, or salvage operations;[108]
   • Russia-related GL-64:  involving Joint-Stock Company Kommersant, or any entity in which Joint-Stock Company Kommersant owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to the operations of the newspaper Kommersant;[109]
   • Russia-related GL-65:  ordinarily incident and necessary to the receipt or transmission of telecommunications involving MegaFon PAO (MegaFon) or Digital Invest Limited Liability Company (Digital Invest), or any entity in which MegaFon or Digital Invest owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest and involving Tajikistan or Uzbekistan, when such transactions would otherwise be prohibited by RuHSR;[110]
   • Russia-related GL-77:  ordinarily incident and necessary to the safe docking and anchoring in port of: Kazan Shipping Incorporated, Progress Shipping Company Limited, or Gallion Navigation Incorporated, and any entity in which any of the aforementioned vessels own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (“blocked vessels”); the preservation of the health or safety of the crew of any of the blocked vessels; or emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels, through 12:01 a.m. eastern standard time, February 14, 2024, provided that any payment to a blocked person must be made into a blocked account in accordance with RuHSR;[111]
   • Russia-related GL-78:  ordinarily incident and necessary to the safe docking and anchoring of Sterling Shipping Incorporated, Streymoy Shipping Limited, HS Atlantic Limited, and any entity in which any of the aforementioned vessels own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (“blocked vessels”); the preservation of the health or safety of the crew of any of the blocked vessels; or emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels, through 12:01 a.m. eastern standard time, February 29, 2024, provided that any payment to a blocked person must be made into a blocked account in accordance with RuHSR;[112]
   • Russia-related GL-79:  ordinarily incident and necessary to the wind down of any transaction involving Limited Liability Company Kyiv Square, Highland Gold Mining Limited, Limited Liability Company Kismet Capital Group, or any entity in which one or more of the aforementioned persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, March 11, 2024, provided that any payment to a blocked person is made into a blocked account in accordance with the RuHSR;[113]
   • Russia-related GL-80:  with certain exceptions noted within the GL, ordinarily incident and necessary to (a) the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity of Highland Gold Mining Limited (Highland Gold), or any entity in which Highland Gold owns, directly or indirectly, a 50 percent or greater interest, purchased prior to December 12, 2023 (“Covered Debt or Equity”), to a non-U.S. person, through 12:01 a.m. eastern daylight time, March 11, 2024; (b) facilitating, clearing, and settling trades of Covered Debt or Equity that were placed prior to 4:00 p.m. eastern standard time, December 12, 2023, through 12:01 a.m. eastern daylight time, March 11, 2024; and (c) the wind down of derivative contracts entered into prior to 4:00 p.m. eastern standard time, December 12, 2023 that (i) include a blocked person described in (a) as a counterparty or (ii) are linked to Covered Debt or Equity, through 12:01 a.m. eastern daylight time, March 11, 2024, provided that any payments to a blocked person are made into a blocked account in accordance with RuHSR;[114]
   • Russia-related GL-81:  ordinarily incident and necessary to (1) the safe docking and anchoring in port of any vessels in which (1) SUN Ship Management D Ltd, (2) Covart Energy Limited, (3) Voliton DMCC, and (4) Bellatrix Energy Limited, and (5) any entity in which any of the foregoing persons owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, has a property interest (“blocked vessels”); (2) the preservation of the health or safety of the crew of any of the blocked vessels; or (3) emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels, through 12:01 a.m. eastern daylight time, March 19, 2024, provided that any payment to a blocked person must be made into a blocked account in accordance RuHSR;[115]
   • Russia-related GL-82:  ordinarily incident and necessary to the wind down of any transaction involving SUN Ship Management D Ltd (SUN Ship), or any entity in which SUN Ship owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, March 19, 2024, provided that any payment to a blocked person is made into a blocked account in accordance RuHSR;[116]
   • Russia-related GL-83A:  ordinarily incident and necessary to the importation into the United States of seafood derivative products, that were loaded onto a vessel at the port of loading prior to 12:01 am eastern standard time on February 20, 2024, pursuant to written contracts or written agreements entered into prior to December 22, 2023, through 12:01 a.m. eastern standard time, May 31, 2024;[117]
   • Russia-related GL-84:  involvingU.S. financial institutions that maintain correspondent accounts or payable-through accounts for any foreign financial institution subject to the correspondent account or payable-through account (CAPTA) prohibition of section 11(b)(i) of Executive Order (E.O.) 14024, as amended, to engage in (1) processing only those transactions through the account, or permitting the foreign financial institution to execute only those transactions through the account, for the purpose of, and necessary for, closing the account; and (2) transferring the funds remaining in the correspondent account or the payable-through account to an account of the foreign financial institution located outside of the United States and closing of the correspondent account or the payable-through account, during the 10-day period beginning on the effective date of the imposition of the prohibition;[118]
   • Russia-related GL-85:  ordinarily incident and necessary to the (i) wind down of any transaction involving Expobank Joint Stock Company (Expobank), or any entity in which Expobank owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, March 21, 2024, provided that any payment to a blocked person is made into a blocked account in accordance with the RuHSR; (ii) closing of an account of a person, wherever located, who is not a blocked person (“the account holder”), held at Expobank, or any financial institution in which Expobank owns, directly or indirectly, a 50 percent or greater interest, and (iii) the unblocking and lump sum transfer of all remaining funds and other assets in the account to the account holder, including to an account of the account holder held at a non-blocked financial institution, through 12:01 a.m. eastern daylight time, March 21, 2024;[119]
   • Russia-related GL-86:  ordinarily incident and necessary to (1) the safe docking and anchoring in port of any vessels in which Hennesea Holdings Limited (Hennesea) or any entity in which Hennesea owns, directly or indirectly, a 50 percent or greater interest, has a property interest (“blocked vessels”); (2) the preservation of the health or safety of the crew of any of the blocked vessels; or (3) emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels, through 12:01 a.m. eastern daylight time, April 17, 2024, provided that any payment to a blocked person must be made into a blocked account in accordance with RuHSR;[120]
   • Russia-related GL-87:  ordinarily incident and necessary to (1) the safe docking and anchoring in port of any vessels in which Oil Tankers SCF MGMT FZCO or NS Leader Shipping Incorporated, and any entity in which any of the aforementioned persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (“blocked persons”), has a property interest (“blocked vessels”); (2) the preservation of the health or safety of the crew of any of the blocked vessels; or (3) emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels involving the blocked persons, through 12:01 a.m. eastern daylight time, May 8, 2024, provided that any payment to a blocked person must be made into a blocked account in accordance with RuHSR;[121]
   • Russia-related GL-88A:  ordinarily incident and necessary to the wind down of any transaction involving one or more of nineteen blocked entities listed within GL 88A, and any entity in which one of those blocked entities owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, April 8, 2024, provided that any payment to a blocked person is made into a blocked account in accordance with RuHSR;[122]
   • Russia-related GL-89:  ordinarily incident and necessary to the wind down of any transaction involving one or more of the eight blocked entities listed with GL 89, and any entity in which one of those blocked entities owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, through 12:01 a.m. eastern daylight time, April 8, 2024, provided that any payment to a blocked person is made into a blocked account in accordance with RuHSR.  Except with some exceptions listed in GL 89, U.S. persons are also authorized to reject, rather than block, and return to the originator, originating financial institution, or their successor-in-interest, all transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the processing of funds involving any blocked financial institution described in GL 89 as an originating, intermediary, or beneficiary financial institution, through 12:01 a.m. eastern daylight time, April 8, 2024;[123]
   • Russia-related GL-90:  ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by the six blocked entities listed within GL 90 (“Covered Debt or Equity), and any entity in which one of those blocked entities owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, to a non-U.S. person, through 12:01 a.m. eastern daylight time, April 8, 2024.  GL 90 does not authorize (1) U.S. persons to sell, or to facilitate the sale of, Covered Debt or Equity to, directly or indirectly, any person whose property and interests in property are blocked; or (2) U.S. persons to purchase or invest in, or to facilitate the purchase of or investment in, directly or indirectly, Covered Debt or Equity, other than purchases of or investments in Covered Debt or Equity ordinarily incident and necessary to the divestment or transfer of Covered Debt or Equity as described in paragraph (a) of GL 90;[124]
   • Russia-related GL-91A:  ordinarily incident and necessary to (1) the safe docking and anchoring in port of any vessels in which Ladoga Shipping Company Limited Liability Company; JSC Polar Marine Geosurvey Expedition; Yuzhmorgeologiya AO; Sevmorneftegeofizika AO; Amige AO; and Joint Stock Company Sovcomflot, and any entity in which any of the aforementioned persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, has a property interest (“blocked vessels”); (2) the preservation of the health or safety of the crew of any of the blocked vessels; or (3) emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels; through 12:01 a.m. eastern daylight time, May 23, 2024, provided that any payment to a blocked person must be made into a blocked account in accordance with RuHSR;[125]
   • Russia-related GL-92:  ordinarily incident and necessary to the delivery and offloading of cargo from any vessel identified on the OFAC’s SDN List that is blocked solely due to a property interest of Joint Stock Company Sovcomflot (Sovcomflot), or any entity in which Sovcomflot owns, directly or indirectly, a 50 percent or greater interest, through 11:59 p.m. eastern daylight time, April 8, 2024, provided that the cargo was loaded prior to February 23, 2024;[126] and
   • Russia-related GL-93:  involving any vessel that is blocked solely due to a property interest of Joint Stock Company Sovcomflot or any entity in which Sovcomflot owns, directly or indirectly, a 50 percent or greater interest, provided that such vessel is not identified on OFAC’s SDN List.[127]

   3.3. Belarus-Related GLs

   In connection with the above-described blocking sanctions, OFAC has issued Belarus GLs permitting certain otherwise prohibited transactions, reissued as 31 C.F.R. § 548.509-514.  These licenses and authorizations cover: emergency medical services;[128] official business of the U.S. government;[129] official business of certain international organizations and entities;[130] certain transactions in support on nongovernmental organizations’ activities;[131] transactions related to the provision of agricultural commodities, medicine, medical devices, replacement part and components, or software updates for personal, non-commercial use;[132] and transactions with the State Security Committee of Belarus.[133]

   4. Export Controls

   The United States has adopted enhanced export control measures on Russia and Belarus.  Since February 24, 2022, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) has issued a series of final rules imposing enhanced export controls on Russia and Belarus under the Export Administration Regulations (“EAR”).[134]  The final rules include the following export control measures:

   • Expanded License Requirement:  A license is now required for the export, reexport or transfer (in country) of items to Russia that are (1) “subject to the EAR”[135] and (2) controlled under any export control classification number (“ECCN”) listed in the Commerce Control List under the EAR, as well as items classified as EAR99 but covered under certain Schedule B/Harmonized Tariff Schedule codes.
   • License Policy of Denial:  Most export license applications for Russia and Belarus will now be subject to a policy of denial.  Applications may be reviewed on a case-by-case basis if they relate to flight safety, maritime safety, humanitarian needs, civil telecommunications infrastructure, government space cooperation and government-to-government activities.
   • Foreign Direct Product (“FDP”) Rules:  The final rules create two new FDP rules that impose licensing requirements for (1) with respect to all of Russia and Belarus, FDPs of certain U.S.-origin software or technology, or plants or components that are FDPs of certain U.S.-origin software or technology (the “Russia/Belarus FDP Rule”), and (2) with respect to Russian and Belarusian military end users, FDPs of any controlled software or technology, or plant or components that are FDPs of controlled software or technology (the “Russia-Belarus-MEU FDP Rule”).[136]
   • Military End Use and End User Controls:  The final rules expandrestrictions on the export, reexport or transfer (in country) of items for Russian and Belarusian military end uses and to certain military end users, including two Belarusian and 49 Russian entities to the Entity List (47 of which were previously on the Military End User List).
   • DNR and LNR Restrictions:  The final rules impose a license requirement for the export, reexport or transfer (in country) of “all items subject to the EAR” (except for certain food and medicine designated as EAR99 (the least restrictive ECCN) and certain software related to Internet-based personal communications) to the DNR and LNR.

   ---

   [1] The information in this summary about economic sanctions is current as of March 6, 2024.  The section in this summary on export controls is being updated to reflect 2023 developments and will be reposted soon.

   [2] Exec. Order No. 14065, “Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine,” 87 Fed. Reg. 10293 (Feb. 21, 2022).

   [3] OFAC, FAQ 1009 (Mar. 2, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1009.

   [4] Exec. Order No. 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation,” 86 Fed. Reg. 20249 (Apr. 15, 2021).  The prohibitions in Executive Order 14024 have been codified in 31 C.F.R. Part 587, Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”).

   [5] Exec. Order No. 14024, Section 1(a)(i), available at https://ofac.treasury.gov/media/57936/download?inline.

   [6] Exec. Order No. 14024, Section 1(a)(i), available at https://ofac.treasury.gov/media/57936/download?inline.

   [7] Determination of February 22, 2022 pursuant to Exec. Order No. 14024, available at https://ofac.treasury.gov/media/918726/download?inline.

   [8] Determination of March 31, 2022 pursuant to Exec. Order No. 14024, available at https://ofac.treasury.gov/media/921226/download?inline.

   [9] Determination of May 8, 2022 pursuant to Exec. Order No. 14024, available at https://ofac.treasury.gov/media/922951/download?inline.

   [10] Determination of September 15, 2022 pursuant to Exec. Order No. 14024, available at https://ofac.treasury.gov/media/926586/download?inline.

   [11] Determination of February 24, 2023 pursuant to Exec. Order No. 14024, available at https://ofac.treasury.gov/media/931336/download?inline.

   [12] Determination of May 19, 2023 pursuant to Exec. Order No. 14024, available at https://ofac.treasury.gov/media/931771/download?inline.

   [13] Executive Order No. 14065, “Blocking Property of Certain Persons and Prohibiting Certain Transactions With

   Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine,” 87 Fed.

   Reg. 10293 (Feb. 21, 2022), available at https://www.federalregister.gov/documents/2022/02/23/2022-04020/blocking-property-of-certain-persons-and-prohibiting-certain-transactions-with-respect-to-continued.

   [14] OFAC, “Russia-related Designations; Issuance of Russia-related Directive 1A and General Licenses; Publication of new and updated Frequently Asked Questions”(Feb. 22, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220222; OFAC, “Russia-related Designations; Belarus Designations; Issuance of Russia-related Directive 2 and 3; Issuance of Russia-related and Belarus General Licenses; Publication of new and updated Frequently Asked Questions” (Feb. 24, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220224; OFAC, “Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses” (Apr. 6, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220406.

   [15] OFAC, “Russia-related Designations and Designation Removal; Cyber-related Designation; CAATSA - Russia-related Designations; Issuance of Russia-related Determination pursuant to Executive Order 14024” (Mar. 31, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220331.

   [16] OFAC, “Russia-related Designations; Issuance of Russia-related Directive 4 and Russia-related General License 8A” (Feb. 28, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220228.

   [17] OFAC, “Russia-related Designations; Publication of new Frequently Asked Question” (Mar. 24, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220324.

   [18] OFAC, “Russia-related Designations and Designations Updates; Publication of Russia-related Frequently Asked Question” (September 30, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220930.

   [19] OFAC, “PEESA Designations; Issuance of Russia-related General License 4” (Feb. 23, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220223_33.

   [20] OFAC, “Russia-related Designations” (Feb. 25, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220225_33; OFAC, “Russia-related Designations; Issuance of Russia-related General License” (Mar. 2, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220303; OFAC, “Issuance of new Russia-related Executive Order and related General Licenses; Publication of new and amended Frequently Asked Questions; Russia-related Designations; North Korea Designations” (Mar. 11, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220311; OFAC, “Russia-related Designations and Designation Update; Belarus Designation and Designation Update; Magnitsky-related Designations” (Mar. 15, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220315; OFAC, “Russia-related Designations; Publication of new Frequently Asked Question” (Mar. 24, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220324; OFAC, “Russia-related Designations” (Apr. 6, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220406_33; OFAC, “Russia-related Designations, Designations Updates, and Designation Removal; Issuance of Russia-related General Licenses; Publication of Russia-related Frequently Asked Questions” (August 2, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220802; OFAC, “Russia-related Designations and Designations Updates; Publication of Russia-related Frequently Asked Question” (September 30, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220930.

   [21] OFAC, “Russia-related Designations; Issuance of Russia-related General License and Frequently Asked Questions; Zimbabwe-related Designation, Removals and Update; Libya-related Designation Update” (September 15, 2022), available at: https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220915.

   [22] OFAC, “U.S. Treasury Targets Belarusian Support for Russian Invasion of Ukraine” (Feb. 24, 2022), available at https://home.treasury.gov/news/press-releases/jy0607.

   [23] OFAC, “Russia-related Designations and Designation Update; Belarus Designation and Designation Update; Magnitsky-related Designations” (Mar. 15, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220315.

   [24] In addition to primary sanctions prohibitions and restrictions on activities undertaken within U.S. jurisdiction, the United States maintains so-called “secondary sanctions” aimed at deterring targeted activity outside of U.S. jurisdiction.  Secondary sanctions technically do not involve a violation of U.S. law; rather, they are a threat that persons engaged in the identified activities contrary to U.S. interests may themselves become the targets of U.S. sanctions:  if a foreign person engages in targeted activity X outside of U.S. jurisdiction, then the United States may impose a menu of potential sanctions ranging from relatively mild to quite severe measures (including designation as an SDN, resulting in blocking all property of, and prohibiting all transactions with, the foreign person within U.S. jurisdiction).  Secondary sanctions can be imposed on non-U.S. persons that undertake a number of activities relating to Russia, including knowingly engaging in significant transactions with parties subject to sanctions under the Russia sanctions program or that provide material assistance or support to SDNs.  No connection to U.S. jurisdiction is required for the imposition of secondary sanctions.  In practice, secondary sanctions involve considerable discretion and political calculation, and they are much more rarely and unpredictably applied than the direct enforcement of U.S. primary sanctions (even when styled as mandatory, as is the case with certain secondary sanctions relating to Russia).

   [25] Russia’s military-industrial base is defined in OFAC’s Determination of December 22, 2023 Pursuant to Section 11(a)(ii) of Executive Order 14024, available at: https://ofac.treasury.gov/media/932446/download?inline.

   [26] OFAC, “Guidance for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia’s Military Industrial Base”( Dec. 22, 2023), available at https://ofac.treasury.gov/media/932436/download?inline.

   [27] OFAC, Determination of December 22, 2023 Pursuant to Section 11(a)(ii) of Executive Order 14024, available at: https://ofac.treasury.gov/media/932446/download?inline.

   [28] “Biden Administration Imposes New Restrictions on Russian Sovereign Debt, Authorizes Additional Sanctions,” Cleary Foreign Investment and International Trade Watch (Apr. 16, 2021), available at https://www.clearytradewatch.com/2021/04/biden-administration-imposes-new-restrictions-on-russian-sovereign-debt-authorizes-additional-sanctions/.

   [29] OFAC, Russia-related Directive 1A Under Executive Order 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Feb. 22, 2022), available at https://ofac.treasury.gov/media/918731/download?inline.

   [30] Under longstanding OFAC guidance, individual sanctions designations flow down to any entity 50 percent or more owned by one or more persons targeted under equivalent sanctions (SDNs, for example).  Under this rule, any entity that is owned, directly or indirectly, 50 percent or more by one or more designated persons is itself considered to be a designated person, regardless of whether the entity itself is listed on the SDN List.  If, however, an entity is not owned, directly or indirectly, 50 percent or more by one or more designated persons, that entity is not considered to be a sanctioned person under the 50 Percent Rule.

   [31] OFAC, FAQ 891 (last updated Feb. 22, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/891.

   [32] “U.S. financial institution” means any U.S. entity (including its foreign branches) that is engaged in the business of accepting deposits, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, futures or options, or procuring purchasers and sellers thereof, as principal or agent.  It includes depository institutions, banks, savings banks, money services businesses, operators of credit card systems, trust companies, insurance companies, securities brokers and dealers, futures and options brokers and dealers, forward contract and foreign exchange merchants, securities and commodities exchanges, clearing corporations, investment companies, employee benefit plans, dealers in precious metals, stones, or jewels, and U.S. holding companies, U.S. affiliates, or U.S. subsidiaries of any of the foregoing.  This term includes those branches, offices, and agencies of foreign financial institutions that are located in the United States, but not such institutions’ foreign branches, offices, or agencies.

   [33] OFAC, Directive 2 Under Executive Order 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Feb. 24, 2022), available at https://ofac.treasury.gov/media/918471/download?inline.

   [34] OFAC FAQ 969 (Feb. 24, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/969.

   [35] OFAC, Directive 3 Under Executive Order 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Feb. 24, 2022), available at https://ofac.treasury.gov/media/918476/download?inline.

   [36] OFAC FAQ 985 (Feb. 24, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/985.

   [37] See OFAC, FAQ 1002 (Mar. 2, 2022, updated May 19, 2023), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1002.

   [38] OFAC, Directive 4 under Executive Order 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” (Feb. 28, 2022), available at https://ofac.treasury.gov/media/918806/download?inline. Amendment available at https://ofac.treasury.gov/media/918806/download?inline (introducing a reporting requirement).

   [39] OFAC, FAQ 1118, (February 24, 2024; updated May 19, 2023), available at https://ofac.treasury.gov/faqs/1118.

   [40] OFAC, FAQ 1004 (Mar. 2, 2022, updated May 19, 2023), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1004.

   [41] OFAC, FAQ 1001 (Mar. 2, 2022, updated May 19, 2023), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1001.

   [42] OFAC, FAQ 1005 (Mar. 2, 2022, updated May 19, 2023), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1005.

   [43] OFAC, Russia-related General License No. 8H, “Authorizing Transactions Related to Energy” (October 25, 2023), available at https://ofac.treasury.gov/media/932246/download?inline.

   [44] Exec. Order No. 14066, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine,” 87 Fed. Reg. 13625 (Mar. 8, 2022).

   [45] OFAC, FAQ 1019 (Mar. 8, 2022), available at https://ofac.treasury.gov/faqs/1019.

   [46] Exec. Order No. 14068, “Executive Order on Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression,” 87 Fed. Reg. 14381 (Mar. 11, 2022), available at https://www.federalregister.gov/documents/2022/03/15/2022-05554/prohibiting-certain-imports-exports-and-new-investment-with-respect-to-continued-russian-federation.

   [47] OFAC, Determination Pursuant to Section 1(a)(i) of Executive Order 14068, “Prohibitions Related to Imports of Gold of Russian Federation Origin (as Amended)” (June 28, 2022), available at https://ofac.treasury.gov/media/923986/download?inline. 

   [48] OFAC, Determination Pursuant to Section 1(a)(i)(B) of Executive Order 14068, “Prohibitions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof” (December 22, 2023), available at https://ofac.treasury.gov/media/932451/download?inline.

   [49] OFAC, Determination Pursuant to Section 1(a)(i)(B) of Executive Order 14068, “Prohibitions Related to Imports of Certain Categories of Diamonds” (February 8, 2024), available at https://ofac.treasury.gov/media/932611/download?inline.

   [50] Exec. Order No. 14071, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression” (Apr. 6, 2022), available at https://www.federalregister.gov/documents/2022/04/08/2022-07757/prohibiting-new-investment-in-and-certain-services-to-the-russian-federation-in-response-to.

   [51] OFAC, Determination pursuant to Exec. Order No. 14071, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and  Management Consulting Services” (May 8, 2022), available at https://ofac.treasury.gov/media/922956/download?inline.  Pursuant to this determination, such services are excepted from the exportation services ban when they are provided (1) to an entity in Russia that is owned or controlled, directly or indirectly, by a U.S. person or (2) in connection with the wind down or divestiture of an entity located in Russia that is not owned or controlled by a Russian person.

   [52] OFAC, Determination pursuant to Exec. Order No. 14071, “Prohibitions Related to Certain Quantum Computing Services” (September 15, 2022),  available at https://ofac.treasury.gov/media/926591/download?inline.

   [53] OFAC, Determination pursuant to Exec. Order No. 14071, “Prohibitions Related to Architecture Services and Engineering Services” (June 18, 2023), available at https://ofac.treasury.gov/media/931776/download?inline. 

   [54] Per OFAC guidance, Discount to Crude products include naphtha, residual  fuel oil, and waste oils.  See OFAC,

   “Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation

   Origin” (February 3, 2023), at 5, available at https://ofac.treasury.gov/media/931036/download?inline.

   [55] Per OFAC guidance, Premium to Crude products include gasoline, motor fuel  blending stock, gasoil and diesel

   fuel, kerosene and kerosene-type jet fuel, and vacuum gas oil.  See OFAC, “Guidance on Implementation of the

   Price Cap Policy for Crude Oil and Petroleum Products of  Russian Federation Origin” (February 3, 2023), at 5,

   available at https://ofac.treasury.gov/media/931036/download?inline.

   [56] OFAC, Determination pursuant to Exec. Order 14071, “Price Cap on Petroleum Products of Russian Federation Origin” (February 5, 2023), available at https://ofac.treasury.gov/media/931026/download?inline.

   [57] OFAC, Determination pursuant to Sections 1(a)(ii), 1(b), and 5 of Exec. Order 14071, “Price Cap on Crude Oil of Russian Federation Origin” (December 5, 2022), available at https://ofac.treasury.gov/media/929776/download?inline.

   [58] OFAC, FAQ 1049 (June 6, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1049.

   [59] OFAC, FAQ 1050 (June 6, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1050.

   [60] OFAC, FAQ 1054 (last updated January 17, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1054.

   [61] OFAC, FAQ 1055 (June 6, 2022, last updated January 17, 2023), available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1055.

   [62] OFAC, “Frequently Asked Questions,” available at https://home.treasury.gov/policy-issues/financial-sanctions/faqs.

   [63] Only general licenses that remain active are listed in this summary – general licenses that have expired by their own terms and have not been renewed by OFAC are not listed.

   [64] OFAC, Ukraine General License No. 18, “Authorizing the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates to Certain Regions of Ukraine and Transactions Related to the Coronavirus Disease 2019 (COVID-19) Pandemic” (Feb. 21, 2022), available at https://ofac.treasury.gov/media/918686/download?inline.

   [65] OFAC, Ukraine General License No. 19, “Authorizing Transactions Related to Telecommunications and Mail” (Feb. 21, 2022), available at https://ofac.treasury.gov/media/918691/download?inline.

   [66] OFAC, Ukraine General License No. 20, “Official Business of Certain International Organizations and Entities” (Feb. 21, 2022), available at https://ofac.treasury.gov/media/918696/download?inline.

   [67] OFAC, Ukraine General License No. 21, “Authorizing Noncommercial, Personal Remittances and the Operation of Accounts” (Feb. 21, 2022), available at https://ofac.treasury.gov/media/918701/download?inline.

   [68] OFAC, Ukraine General License No. 22, “Authorizing the Exportation of Certain Services and Software Incident to Internet-Based Communications” (Feb. 21, 2022), available at https://ofac.treasury.gov/media/918706/download?inline.

   [69] OFAC, Ukraine General License No. 23, “Certain Transactions in Support of Nongovernmental Organizations’ Activities” (March 11, 2022), available at https://ofac.treasury.gov/media/919151/download?inline.

   [70] OFAC, “Issuance of Russia-related General License 24; Publication of amended Frequently Asked Question” (Mar. 18, 2022), available at https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220318_33.

   [71] OFAC, Ukraine/Russia-related General License No. 25, “Journalistic Activities and Establishment of News Bureaus in Certain Regions of Ukraine” (Mar. 24, 2022), available at https://ofac.treasury.gov/media/920276/download?inline.

   [72] OFAC, Russia-related General License 1A, “Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue Service” (August 20, 2021), available at https://ofac.treasury.gov/media/912351/download?inline.

   [73] On August 20, 2021, OFAC determined that Russia-related General License No. 1A replaced and superseded in its entirety Russia-related General License No. 1.

   [74] OFAC, Russia-related General License No. 2, “Authorizing Certain Servicing Transactions Involving State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank” (Feb. 22, 2022), available at https://ofac.treasury.gov/media/918631/download?inline.

   [75] On March 24, 2022, OFAC amended prior Russia-related GL-6 to cover ongoing clinical trials and other medical research activities that were in effect prior to March 24, 2022.  On July 14, 2022, OFAC amended prior Russia-related GL-6A to broaden the scope of its coverage.

   [76] OFAC, Russia-related General License No. 6B, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials” (July 14, 2022), available at https://ofac.treasury.gov/media/924321/download?inline.  The current version in effect is GL-6C (January 17, 2023), available at https://ofac.treasury.gov/media/930431/download?inline.

   [77] On May 5, 2022, OFAC amended prior Russia-related GL-7 to exclude any debit to an account on the books of a U.S. financial institution of the Russian Central Bank, Russian Ministry of Finance or Russian National Wealth Fund from the scope of the GL.

   [78] OFAC, Russia-related General License No. 7A, “Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services” (May 5, 2022), available at https://ofac.treasury.gov/media/922841/download?inline.

   [79] On April 6, 2022, OFAC amended prior Russia-related GL-8A to add Alfa-Bank to the list of covered entities.

   [80] On February 28, 2022, OFAC amended prior Russia-related GL-8 to add the Russian Central Bank.

   [81] OFAC, Russia-related General License No. 8C, “Authorizing Transactions Related to Energy” (June 14, 2022, available at https://ofac.treasury.gov/media/923821/download?inline.

   [82] On June 14, OFAC determined that Russia-related General License No. 8B was replaced and superseded in its entirety by Russia-related General License No. 8C. Russia-related General License 8B was set to expire on June 24, 2022. The current version in effect is GL-8H (October 25, 2023), available at https://ofac.treasury.gov/media/932246/download?inline.

   [83] On May 25, 2022 OFAC amended prior Russia-related GL-13 to exclude any transactions otherwise prohibited by RuHSR (unless separately authorized) from the scope of the GL. On September 8, 2022, OFAC amended prior

   Russia-related GL-13A to update the cut-off for authorized transactions. September 30, 2022 was updated to

   December 7, 2022. The current version in effect is GL-13H (effective January 18, 2024), available at https://ofac.treasury.gov/media/932541/download?inline.

   [84] OFAC, Russia-related General License No. 14, “Authorizing Certain Clearing and Settlement Transactions Prohibited by Directive 4 under Executive Order 14024” (Mar. 2, 2022), available at https://ofac.treasury.gov/media/918896/download?inline.

   [85] OFAC, Russia-related General License No. 18, “Authorizing U.S. Dollar-Denominated Banknote Noncommercial, Personal Remittances Prohibited by Executive Order of March 11, 2022 Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression” (Mar. 11, 2022), available at https://ofac.treasury.gov/media/919081/download?inline.

   [86] OFAC, Russia-related General License No. 19, “Authorizing Transactions Related to Personal Maintenance of U.S. Individuals Located in the Russian Federation Prohibited by Executive Order of March 11, 2022 Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression” (Mar. 11, 2022), available at https://ofac.treasury.gov/media/919086/download?inline.

   [87] OFAC, Russia-related General License No. 20, “Authorizing Third-Country Diplomatic and Consular Funds Transfers” (Mar. 24, 2022), available at https://ofac.treasury.gov/media/920271/download?inline.

   [88] On May 8, 2022, OFAC amended prior Russia-related GL-25 to exclude any transactions involving Channel One Russia, NTV Broadcasting Company, or Television Station Russia-1 (unless separately authorized) from the scope of the GL.  On June 2, 2022, OFAC amended prior Russia-related GL-25A to exclude any transactions with Algoritm (unless separately authorized) from the scope of the GL.  On July 14, 2022, OFAC amended prior Russia-related GL-25B to exclude any transactions with New Eastern Outlook or Oriental Review (unless separately authorized) from the scope of the GL.

   [89] OFAC, Russia-related General License No. 25C, “Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications” (July 14, 2022), available at https://ofac.treasury.gov/media/924326/download?inline.

   [90] OFAC, Russia-related General License No. 27, “Certain Transactions in Support of Nongovernmental Organizations’ Activities” (Apr. 19, 2022), available at https://ofac.treasury.gov/media/922211/download?inline.

   [91] OFAC, Russia-related General License No. 31, “Authorizing Certain Transactions Related to Patents, Trademarks, and Copyrights” (May 5, 2022), available at https://ofac.treasury.gov/media/922851/download?inline.

   [92] OFAC, Russia-related General License No. 38A, “Authorizing Transactions Related to Pension Payments” (August 19, 2022), available at https://ofac.treasury.gov/media/925321/download?inline.

   [93] On August 19, 2022 OFAC determined that Russia-related General License No. 38A replaced and superseded in its entirety by Russia-related General License No. 38. Russia-related General License 38A added the non-US persons aspect of this license to Russia-related General License 38, which only discussed all transactions ordinarily incident and necessary to the processing of pension payments to U.S. persons only. OFAC, Russia-related General License No. 38, “Authorizing Transactions Related to Pension Payments to U.S. Persons” (June 2, 2022), available at https://ofac.treasury.gov/media/925321/download?inline.

   [94] On August 3, 2022, OFAC determined that Russia-related General License No. 40B replaced and superseded in its entirety Russia-related General License No. 40A, dated August 2, 2022. On August 2, 2022, OFAC determined that Russia-related General License No. 40A replaced and superseded in its entirety Russia-related General License No. 40, dated June 28, 2022. The difference between the two documents was the changing of the name of a blocked entity. Joint Stock Company Government Transport Company was changed to Joint Stock Company State Transportation Leasing Company. On November 14, 2022, OFAC issued GL-40C to replace GL-40B, available at https://ofac.treasury.gov/media/929386/download?inline.

   [95] Section (1)(i) of Russia-related GL-42 does not authorize the exportation, reexportation, or provision of goods or technology to or on behalf of the Federal Security Service, except as provided in Section (1)(i).

   [96] OFAC, Russia-related General License No. 42 “Authorizing Certain Transactions with the Federal Security Service” (June 28, 2022) available at https://ofac.treasury.gov/media/923976/download?inline.

   [97] On June 28, 2022 OFAC added the following note to Russia-related General License No. 42: The exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of any goods, services, or technology to the so-called “Donetsk People’s Republic” or “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, pursuant to E.O. 14065, or to the Crimea region of Ukraine remain prohibited pursuant to authorities implemented by the Ukraine-/Russia-Related Sanctions Regulations, 31 CFR part 589.

   [98] OFAC, Russia-related General License No. 44, “Authorizing the Export or Reexport of Certain Accounting Services to U.S. Individuals Located in the Russian Federation” (July 14, 2022), available at https://ofac.treasury.gov/media/924336/download?inline.

   [99] OFAC, Russia-related General License No. 46, “Authorizing Transactions in Support of an Auction Process to Settle Certain Credit Derivative Transactions Prohibited by Executive Order 14071” (July 22, 2022), available at https://ofac.treasury.gov/media/924546/download?inline.

   [100] OFAC, Russia-related General License No. 50, “Authorizing the Closing of Individual Accounts at Financial Institutions Blocked Pursuant to Executive Order 14024” (August 19, 2022), available at https://ofac.treasury.gov/media/925326/download?inline.

   [101]  According to OFAC, for the purposes of this general license, the term “news reporting organization”

   means an entity whose primary purpose is the gathering and dissemination of news to the general

   public.

   [102] OFAC, Russia-related General License No. 52, “Journalistic Activities and Establishment of News Bureaus” (September 15, 2022), available at https://ofac.treasury.gov/media/926581/download?inline.

   [103] OFAC, Russia-related General License No. 53, “Authorizing Transactions for Diplomatic Missions of the Russian Federation Prohibited by Directive 4 under Executive Order 14024” (November 10, 2022), available at https://ofac.treasury.gov/media/929331/download?inline.

   [104]  OFAC, Russia-related General License No. 54A, “Authorizing Certain Transactions Involving VEON Ltd. or VEON Holdings B.V. Prohibited by Executive Order 14071” (January 17, 2023), available at https://ofac.treasury.gov/media/930441/download?inline.

   [105] OFAC, Russia-related General License No. 55, “Authorizing Certain Services Related to Sakhalin-2” (November 22, 2022), available at https://ofac.treasury.gov/media/929461/download?inline.

   [106] The most recent version of this GL, GL55A, which superseded GL 55, is available at https://ofac.treasury.gov/media/932136/download?inline.

   [107] OFAC, Russia-related General License No. 56A, “Authorizing Certain Services with Respect to the European Union” (February 3, 2023), available at https://ofac.treasury.gov/media/931011/download?inline.

   [108] OFAC, Russia-related General License No. 57A, “Authorizing Certain Services Related to Vessel Emergencies” (February 3, 2023), available at https://ofac.treasury.gov/media/931016/download?inline.

   [109] OFAC, Russia-related General License No. 64, “Authorizing Certain Transactions Involving Kommersant” (April 12, 2023), available at https://ofac.treasury.gov/media/931616/download?inline.

   [110] OFAC, Russia-related General License No. 65, “Authorizing Transactions Related to Telecommunications and Certain Internet-based Communications Involving Megafon PAO or Digital Invest Limited Liability Company” (April 12, 2023), available at https://ofac.treasury.gov/media/931621/download?inline.

   [111] OFAC, Russia-related General License No. 77, “Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels” (November 16, 2023), available at https://ofac.treasury.gov/media/932336/download?inline.

   [112] OFAC, Russia-related General License No. 78, “Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on December 1, 2023” (December 1, 2023), available at https://ofac.treasury.gov/media/932361/download?inline.

   [113] OFAC, Russia-related General License No. 79, “Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on December 12, 2023” (December 12, 2023), available at  https://ofac.treasury.gov/media/932396/download?inline.

   [114] OFAC, Russia-related General License No. 80, “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Highland Gold Mining Limited” (December 12, 2023), available at https://ofac.treasury.gov/media/932401/download?inline.

   [115] OFAC, Russia-related General License No. 81, “Authorizing Limited Safety and Environmental Transactions

   Involving Certain Persons or Vessels Blocked on December 20, 2023” (December 20, 2023), available at https://ofac.treasury.gov/media/932461/download?inline.

   [116] OFAC, Russia-related General License No. 82, “Authorizing the Wind Down of Transactions Involving SUN Ship Management D Ltd” (December 20, 2023), available at https://ofac.treasury.gov/media/932466/download?inline.

   [117] OFAC, Russia-related General License No. 83A, “Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068” (February 20, 2023), available at https://ofac.treasury.gov/media/932636/download?inline.

   [118] OFAC, Russia-related General License No. 84, “Authorizing Transactions Related to Closing a Correspondent or Payable-Through Account” (December 22, 2023), available at https://ofac.treasury.gov/media/932476/download?inline.

   [119] OFAC, Russia-related General License No. 85, “Authorizing the Wind Down of Transactions and the Closure of Accounts Involving Expobank Joint Stock Company” (December 12, 2023), available at https://ofac.treasury.gov/media/932481/download?inline.

   [120] OFAC, Russia-related General License No. 86, Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on January 18, 2024” (January 18, 2024), available at https://ofac.treasury.gov/media/932546/download?inline.

   [121] OFAC, Russia-related General License No. 87, “Authorizing Limited Safety and Environmental Transactions Involving Certain Persons or Vessels Blocked on February 8, 2024” (February 8, 2024), available at https://ofac.treasury.gov/media/932601/download?inline.

   [122] OFAC, Russia-related General License No. 88A, “Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on February 23, 2024” (February 23, 2024) , available at https://ofac.treasury.gov/media/932671/download?inline.

   [123] OFAC, Russia-related General License No. 89, “Authorizing the Wind Down and Rejection of Transactions Involving Certain Financial Institutions Blocked on February 23, 2024” (February 23, 2024), available at https://ofac.treasury.gov/media/932646/download?inline.

   [124] OFAC, Russia-related General License No. 90, “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on February 23, 2024” (February 23, 2024), available at https://ofac.treasury.gov/media/932651/download?inline.

   [125] Russia-related General License No. 91, “Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked Persons or Vessels” (February 23, 2024), available at https://ofac.treasury.gov/media/932676/download?inline.

   [126] Russia-related General License No. 92, “Authorizing the Offloading of Cargo from Sovcomflot Vessels” (February 23, 2024), available at https://ofac.treasury.gov/media/932661/download?inline.

   [127] Russia-related General License No. 93, “Authorizing Certain Transactions Involving Certain Sovcomflot Vessels” (February 23, 2024), available at https://ofac.treasury.gov/media/932666/download?inline.

   [128] 31 C.F.R. § 548.509, available at https://www.ecfr.gov/current/title-31/part-548/section-548.509.

   [129] 31 C.F.R. § 548.510, available at https://www.ecfr.gov/current/title-31/section-548.510.

   [130] 31 C.F.R. § 548.511, available at https://www.ecfr.gov/current/title-31/section-548.511.

   [131] 31 C.F.R. § 548.512, available at https://www.ecfr.gov/current/title-31/section-548.512.

   [132] 31 C.F.R. § 548.513, available at https://www.ecfr.gov/current/title-31/section-548.513.

   [133] 31 C.F.R. § 548.514, available at https://www.ecfr.gov/current/title-31/section-548.514.

   [134] U.S. Department of Commerce, Bureau of Industry and Security, Final Rule, “Implementation of Sanctions Against Russia Under the Export Administration Regulations” (Feb. 24, 2022), available at https://www.federalregister.gov/documents/2022/03/03/2022-04300/implementation-of-sanctions-against-russia-under-the-export-administration-regulations-ear; U.S. Department of Commerce, Bureau of Industry and Security, Final Rule, “Imposition of Sanctions Against Belarus Under the Export Administration Regulations” (Mar. 8, 2022), available at https://www.federalregister.gov/documents/2022/03/08/2022-04819/imposition-of-sanctions-against-belarus-under-the-export-administration-regulations-ear; U.S. Department of Commerce, Bureau of Industry and Security, Final Rule, “Expansion of Sanctions Against Russia and Belarus Under the Export Administration Regulations” (Scheduled to be Published on Apr. 14, 2022), available at https://public-inspection.federalregister.gov/2022-07937.pdf; U.S. Department of Commerce, Bureau of Industry and Security, Final Rule, “Expansion of Sanctions Against Russian Industry Sectors Under the Export Administration Regulations (EAR)” (May 9, 2022), available at https://www.federalregister.gov/documents/2022/05/11/2022-10099/expansion-of-sanctions-against-russian-industry-sectors-under-the-export-administration-regulations.

   [135] This includes all items in the United States and all U.S.-origin items, wherever located, foreign-made items that incorporate controlled U.S.-origin content above certain de minimis levels, and certain “foreign direct products” of U.S.-origin technology or software.

   [136] The new FDP Rules exempt the following countries from certain requirements:  Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, New Zealand, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom.