OFAC CHANGES TO GENERAL LICENCES AND FAQ

OFAC: NEW RUSSIA SANCTIONS GENERAL LICENSES

On 19 May, OFAC announced –

General License 13E – Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024;

General License 66 – Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Polyus;

General License 67 – Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Public Joint Stock Company Polyus; and

General License 68 – Authorizing the Wind Down of Transactions Involving Certain Universities and Institutes.

https://ofac.treasury.gov/media/931786/download?inline

https://ofac.treasury.gov/media/931791/download?inline

https://ofac.treasury.gov/media/931796/download?inline

https://ofac.treasury.gov/media/931801/download?inline

OFAC IMPOSES AN ADDITIONAL REPORTING REQUIREMENT ON US PERSONS TO IDENTIFY ASSETS OF ENTITIES SUBJECT TO RUSSIA-RELATED SANCTIONS

On 19 May, OFAC advised that Directive 4 – 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 – had been amended.  Amended FAQ 998 to 1002, 1004, 1005, and 1118 also refer.  US persons must submit a report on or before 18 June, and annually thereafter, on property in their possession or control with an interest, direct or indirect of an entity subject to Russia-related Directive 4, as amended (see FAQ 998).  Note that existing licenses or authorisations issued by OFAC pursuant to the prior version of Russia-related Directive 4 remain in effect.

https://ofac.treasury.gov/media/918806/download?inline

https://ofac.treasury.gov/faqs/search/998+999+1000+1001+1002

https://ofac.treasury.gov/faqs/search/1004+1005

https://ofac.treasury.gov/faqs/1118

OFAC: 2 NEW DETERMINATIONS OVER RUSSIA SANCTIONS

On 19 May, OFAC issued 2 new Determinations –

Architecture, Engineering, Construction, Manufacturing, and Transportation Sectors of the Russian Federation Economy; and

Prohibitions Related to Architecture Services and Engineering Services.

OFAC is also publishing 3 associated FAQ and removing FAQ 964, 1037, and 1085, which were incorporated into new FAQ 1126 to 1128.  OFAC has also amended FAQ 1059, 1061 and 1062.

https://ofac.treasury.gov/media/931771/download?inline

https://ofac.treasury.gov/media/931776/download?inline

https://ofac.treasury.gov/faqs/search/1126+1127+1128

https://ofac.treasury.gov/faqs/1059

https://ofac.treasury.gov/faqs/search/1061+1062

OFAC: AMENDED FAQ RE BLOCKING SANCTIONS ISSUED BY THE STATE DEPARTMENT ON POLIMETALL AO

On 19 May, OFAC reported that FAQ 1129 had been amended.  The FAQ says that the State Department designated Russia-based Polimetall AO on 19 May, and that the blocking sanctions apply only to this entity and any entities in which it owns, directly or indirectly, a 50% or greater interest.  

https://ofac.treasury.gov/faqs/1129

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

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: