U.S. executive order, Ukraine-related general licenses

Concerning Russian efforts to undermine the sovereignty and territorial integrity of Ukraine

Concerning Russian efforts to undermine the sovereignty and territorial integrity of Ukrai

President Biden has signed an executive order concerning Russian efforts to undermine the sovereignty and territorial integrity of Ukraine.

Read the executive order [PDF 100 KB] on blocking property of certain persons and prohibiting certain transactions

According to a White House release, the executive order prohibits:

  • New investment in the Donetsk or Luhansk regions of Ukraine by a U.S. person, wherever located
  • The importation into the United States, directly or indirectly, of any goods, services, or technology from the Donetsk or Luhansk regions of Ukraine
  • The exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of any goods, services, or technology to the Donetsk or Luhansk regions of Ukraine
  • Any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be covered by these prohibitions if performed by a U.S. person or within the United States

The executive order also provides authority to impose sanctions on persons determined:

  • To operate or have operated since February 21, 2022 (the date of the order) in the Donetsk or Luhansk regions of Ukraine
  • To be or have been since February 21, 2022, a leader, official, senior executive officer, or member of the board of directors of an entity operating in the Donetsk or Luhansk regions of Ukraine
  • To be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to the executive order
  • To have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to the executive order


In addition, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has issued six general licenses related to Ukraine:

  • Ukraine General License 17: Authorizing the wind down of transactions involving the Donetsk or Luhansk regions of Ukraine
  • Ukraine General License 18: Authorizing the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates to certain regions of Ukraine and transactions related to the coronavirus disease 2019 (COVID-19) pandemic
  • Ukraine General License 19: Authorizing transactions related to telecommunications and mail
  • Ukraine General License 20: Official business of certain international organizations and entities
  • Ukraine General License 21: Authorizing noncommercial, personal remittances and the operation of accounts
  • Ukraine General License 22: Authorizing the exportation of certain services and software incident to internet-based communications

Read the OFAC release (February 21, 2022)


OFAC today also published Russia-related:

  • Directive 1A under Executive Order 14024
  • General License 2: Authorizing certain servicing transactions involving state corporation bank for development and foreign economic affairs Vnesheconombank
  • General License 3: Authorizing the wind down of transactions involving state corporation bank for development and foreign economic affairs Vnesheconombank
  • General License 4: Authorizing the wind down of transactions involving Nord Stream 2 AG—read the OFAC release (added February 23, 2022)
  • “Frequently asked question” (FAQ) 964
  • FAQ 965
  • Updated FAQs

Read the OFAC release (February 22, 2022)
 

For more information, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
Principal
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
Principal
T: 312-665-3229
E: christopheryoung@kpmg.com

Gisele Belotto
Principal
T: 305-913-2779
E: gbelotto@kpmg.com

George Zaharatos
Principal
T: 404-222-3292
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
T: 313-230-3080
E: adoornaert@kpmg.com

Jessica Libby
Principal
T: 612-305-5533
E: jlibby@kpmg.com

 

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