United States releases Russia-related general licenses, updated set of FAQs

OFAC issued Russia-related general licenses and updated a set of “frequently asked questions” (FAQs).

OFAC issued Russia-related general licenses and updated a set of FAQs

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today issued Russia-related general licenses and updated a set of “frequently asked questions” (FAQs).

  • Read the OFAC release
  • Read Russia-related: 
    • General License 6A [PDF 160 KB] Transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, the coronavirus disease 2019 (COVID-19) pandemic, or clinical trials
    • General License 17A [PDF 132 KB] Authorizing transactions related to certain imports prohibited by Executive Order 14068
    • General License 20 [PDF 1532 KB] Authorizing third-country diplomatic and consular funds transfers
  • Read Ukraine-/Russia-related General License 25 [PF 137 KB] Journalistic activities and establishment of news bureaus in certain regions of ukraine
  • Read two updated FAQs (full text provided below)

 

Russian Harmful Foreign Activities Sanctions

1,024. I have a shipment of a certain product(s) listed in Executive Order (E.O.) 14068 en route to the United States that were contracted prior to March 11, 2022.  Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product(s) and comply with the import ban?

Yes.  E.O. 14068 prohibits the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; and non-industrial diamonds of Russian Federation origin.  It does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the United States that were previously destined for the United States.

In addition, the Office of Foreign of Assets Control (OFAC) has issued Russia-related General License (GL) 17A to authorize the import, for a limited time, of certain items pursuant to pre-existing written contracts or written agreements (see FAQ 1023).  GL 17A provides such authorization for importing alcoholic beverages or non-industrial diamonds of Russian Federation origin through March 25, 2022 and authorization for importing fish, seafood, and preparations thereof of Russian Federation origin through June 23, 2022.  OFAC may issue specific licenses on a case-by-case basis to authorize shipments occurring after the expiry of GL 17A or for other activity outside the scope of this GL.

(Updated March 24, 2022)

Updated on 03/24/2022

 

Russian Harmful Foreign Activities Sanctions

1,023. Is there a period of time for U.S. persons to continue importing products prohibited by Executive Order (E.O.) 14068?

Russia-related General License (GL) 17A  authorizes through March 25, 2022 transactions that are ordinarily incident and necessary to the importation into the United States of alcoholic beverages or non-industrial diamonds of Russian Federation origin pursuant to written contracts or written agreements entered into prior to March 11, 2022.  GL 17A also authorizes through June 23, 2022 transactions that are ordinarily incident and necessary to the importation into the United States of fish, seafood, and preparations thereof of Russian Federation origin pursuant to written contracts or written agreements entered into prior to March 11, 2022.  GL 17A does not authorize entry into new contracts.

Additionally, E.O. 14068 does not prohibit transactions such as the unwinding of contracts or other business-related activities by U.S. persons to comply with the import ban imposed under E.O. 14068.  Likewise, E.O. 14068 does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments outside the United States of prohibited imports previously destined for the United States.

Note that other prohibitions specified in E.O. 14068 are effective immediately. Additionally, with respect to the export prohibitions set forth in section 1(a)(ii) of E.O. 14068, please consult the U.S. Department of Commerce, Bureau of Industry and Security, for guidance.

(Updated March 24, 2022)

 Updated on 03/24/2022

 

For more information, contact a professional with KPMG’s Trade & Customs services:

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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