OFAC Reissues and Expands General License Authorizing Certain Transactions Involving the Central Bank of Russia, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation
On May 25, 2022, the United States Department of Treasury’s Office of Foreign Assets Control Posted Related to Russia 13A General License“Authorization of Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024” (“GL 13A”), which amends and replaces former GL 13. Our previous blog post on GL 13 can be found here.
Consistent with GL 13, GL 13A continues to permit, under certain conditions, U.S. Persons to pay taxes, fees, or import duties and to purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions would otherwise be prohibited. on the basis that they involve the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation or the Ministry of Finance of Russia, and provided that such transactions are habitually incidental and necessary for the day-to-day operations of these people in Russia.
GL 13A has been amended to state that the authorizations described above apply to “entities owned or controlled, directly or indirectly, by a US Person”. This appears to clarify that GL 13A permits the involvement of a US Person in activities covered by GL 13A (eg, payment of import duties) that are conducted by non-US affiliates of US Persons.
GL 13A’s clearance has also been extended until 12:01 a.m. Eastern Time on September 30, 2022.
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