OFAC imposed a new round of sanctions targeting economic sectors that generate "substantial revenue" for the Russian regime. These actions were taken in conjunction with State Department sanctions. In connection with this, OFAC issued three new and two amended General Licenses ("GLs") authorizing (i) transactions ordinarily incident and necessary to certain financial contracts with Russian Federation entities and certain export agreements with Russian Federation entities and (ii) the wind down of transactions involving certain individuals on OFAC's SDN List.
The new and amended GLs, issued under the "Russian Harmful Foreign Activities Sanctions Regulations" (31 CFR Part 587), include following:
- GL 40A authorizes all transactions ordinarily incident and necessary to the provision of exports to ensure the safety of civil aviation involving certain entities on OFAC's SDN List, provided that (i) the aircraft is registered in a jurisdiction solely outside of the Russian Federation and (ii) the exports that are provided are for use on aircrafts operated solely for civil aviation purposes.
- GL 43A authorizes all transactions prohibited by E.O. 14024 ("Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation") that are ordinarily incident and necessary to the divestment of debt or equity of Public Joint Stock Company Severstal or Nord Gold PLC, or any of their subsidiaries, through 12:01am EDT on August 31, 2022.
- GL 47 authorizes the wind down of transactions involving certain entities added to OFAC's SDN List on August 2, 2022. The transactions are prohibited through 12:01 a.m. EDT on September 1, 2022, provided that any payment to a blocked person must be made into a blocked account in accordance with Russian Sanctions Regulations.
- GL 48 authorizes transactions related to the divestment of debt or equity of and wind-down of derivative contracts involving certain entities recently added to OFAC's SDN List through 12:01 a.m. EDT on October 3, 2022.
- GL 49 authorizes transactions ordinarily incident and necessary to the wind down of any transaction involving MMK Metalurji Sanayi Ticaret Ve Liman Isletmeciligi Anonim Sirketi or any entity it owns, through 12:01 a.m. EST on January 31, 2023.