U.S. sanctions regarding Russia, general licenses and FAQs

Treasury’s Office of Foreign Assets Control issued Russia-related general licenses, updated set of FAQs

Russia-related general licenses, updated set of FAQs

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today issued four Russia-related general licenses.

  • General License 7A [PDF 153 KB]—Authorizing overflight payments, emergency landings, and air ambulance services
  • General License 26A [PDF 158 KB]—Authorizing the wind down of transactions involving joint stock company SB Sberbank Kazakhstan, Sberbank Europe AG, or Sberbank (Switzerland) AG
  • General License 31 [PDF 152 KB]—Authorizing certain transactions related to patents, trademarks, and copyrights
  • General License 32 [PDF 153 KB]—Authorizing the wind down of transactions involving Amsterdam Trade Bank NV

In addition, OFAC published one new ”frequently asked question” (FAQ) and amended one FAQ (full text of the FAQs provided below).
 

New FAQ

1032. On April 20, 2022, Transkapitalbank (TKB) was designated pursuant to Russia-related Executive Order 14024.  Can U.S. persons continue to engage in Afghanistan-related transactions with TKB?

Yes.  The Office of Foreign Assets Control (OFAC) issued two general licenses (GLs) related to TKB, which allow U.S. persons to engage in certain transactions involving TKB for specified time periods.

Russia-related GL 28 authorizes U.S. persons to engage in certain transactions involving TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, that are ultimately destined for or originating from Afghanistan through 12:01 a.m. eastern daylight time, October 20, 2022. 

GL 28 also authorizes U.S. financial institutions to operate correspondent accounts on behalf of TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, provided such accounts are used solely to effect transactions ultimately destined for or originating from Afghanistan that are authorized by the GL.  This means that U.S. financial institutions are authorized to debit or credit correspondent accounts maintained for TKB, provided these debits or credits are for payments that are ultimately destined for or originating from Afghanistan.

In addition, through 12:01 a.m. eastern daylight time, May 20, 2022, Russia-related GL 29 authorizes certain transactions ordinarily incident and necessary to the wind down of transactions involving TKB, or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, regardless of whether such transactions are related to Afghanistan.  GL 29 does not authorize debits to blocked accounts.  For more information, please see FAQ 990.

For further information on relevant authorizations, exemptions, and public guidance, please review OFAC’s Fact Sheets, “Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine” and “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People.”

Date Released

May 5, 2022
 

Amended FAQ

1009. Does Executive Order (E.O.) 14065 block the entire Donetsk and Luhansk oblasts?

No.  E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”).  In determining whether a location is within the regions subject to sanctions, U.S. persons may reasonably rely on vetted information from reliable third parties, such as postal codes and maps.

U.S. persons engaging in activity that does not involve the Covered Regions are not subject to the prohibitions in E.O. 14065.  Please see FAQ 1006 for what prohibitions apply to the Covered Regions. 

Date Updated: May 05, 2022

March 2, 2022
 

For more information on sanctions and other responses to Russia’s war on Ukraine, visit KPMG’s dedicated website.



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