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Financial Services Law Insights and Observations

OFAC issues new Russia-related general license, will not renew general license concerning debt or equity dealings with certain Russian financial institutions

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

Financial Crimes

On May 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 13A, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024.” Specifically, GL 13A permits U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person “to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications” for certain transactions normally prohibited by Directive 4, “provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities.” GL 13A expires September 30 at 12:01 am EDT.

The day before, OFAC announced that provisions of GL 9C, issued pursuant to the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), will not be renewed. As previously covered by InfoBytes, GL 9C was issued last month to authorize transactions “ordinarily incident and necessary to dealings in debt or equity” issued before February 24, 2022 involving certain Russian financial institutions that would otherwise be prohibited by the RuHSR. GL 9C expires on May 25 at 12:01 am EDT.