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Financial Services Law Insights and Observations

OFAC amends cyber-related general license and related FAQs

Financial Crimes OFAC Department of Treasury Sanctions Of Interest to Non-US Persons OFAC Designations

Financial Crimes

On March 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued cyber-related General License (GL) 1B, “Authorizing Certain Transactions with the Federal Security Service,” which authorizes certain transactions and activities that are “necessary and ordinarily incident” to the “[r]equesting, 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 the Russian Federation,” provided certain criteria are met. OFAC also published three amended FAQs related to GL 1B (see 501, 502, and 503). Effective March 2, GL 1B supersedes and replaces GL 1A, which was issued in 2018 and covered by InfoBytes here.