OFAC ISSUES NEW UKRAINE/RUSSIA SANCTIONS FAQ

On 14th September, OFAC advised of an update to the FAQ to provide guidance on “maintenance” as that term is used in General Licenses (GL) 14, 15 and 16, with new FAQ 625 and 626  The authorisation for “maintenance” is said to generally includes all transactions and activities ordinarily incident to performing under a contract or agreement in effect prior to April 6th 2018, provided that the level of performance is consistent with the terms of the general licence and consistent with past practices that existed between the party and the blocked entity prior to April 6th 2018.  It may also cover situations where there was no contract or agreement, in a manner consistent with the terms of the general licence and consistent with past practices that existed between the party and the blocked entity prior to April 6th 2018.

https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_other.aspx#625

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20180914_33.aspx

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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