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Financial Services Law Insights and Observations

Treasury releases fact sheet on providing food and humanitarian support to persons impacted by Russian invasion of Ukraine

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

Financial Crimes

On April 19, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued a Fact Sheet ​for “Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine” following an event on the topic held by OFAC. The Fact Sheet, among other things, highlights Treasury’s humanitarian-related or other general licenses (GL) issued to support of the people impacted by Russia’s war related to: (i) telecommunications and internet-based communications; (ii) Covid-19 and clinical trials; (iii) NGO activities; (iv) personal remittances; (v) personal maintenance of U.S. individuals; (vi) emergency medical services; (vii) government and international organization official business; (viii) overflight payments, emergency landings, and air ambulance services; (ix) civil maritime services in the Donetsk and Luhansk regions; and (x) journalistic activities.

The same day, OFAC issued a new Russia-related GL 27, “Certain Transactions in Support of Nongovernmental Organizations’ Activities,” to authorize transactions related to certain activities of NGOs in Russia and Ukraine.