A Summary of Newly Issued Russia-Related General Licenses and FAQs

This Client Alert covers General Licenses 53A, 55C, 113 and 114 and Frequently Asked Questions 1201 and 1202

General Licenses

Houston, Tex. (January 17, 2025) - The U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) recently issued a series of General Licenses, including Russia-related GL 53A, Russia-related GL 55C, Russia-related GL 113, and Russia-related GL 114.  

Russia-related GL 53A, “Authorizing Transactions for Diplomatic Missions of the Russian Federation Involving Gazprombank Joint Stock Company or Prohibited by Directive 4 under Executive Order 14024." Under GL 53A, U.S. persons are authorized to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation that are prohibited by Executive Order (E.O.) 14024 and involve Gazprombank Joint Stock Company (“Gazprombank”), or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest.

Russia-related GL 55C, “Authorizing Certain Services Related to Sakhalin-2.” Sakhalin-2 is an oil and gas development in Sakhalin Island, Russia. It includes development of the Piltun-Astokhskoye oil field and the Lunskoye natural gas field offshore Sakhalin Island in the Okhotsk Sea, which is Russia’s first liquefied natural gas plant, and associated infrastructure onshore. Under Russia-related GL 55C, all transactions prohibited by the determination of November 21, 2022 made pursuant to section 1(a)(ii) of Executive Order (E.O.) 14071 (“Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil of Russian Federation Origin”) related to the maritime transport of crude oil originating from the Sakhalin-2 project (“Sakhalin-2 byproduct”) are authorized through 12:01 a.m. eastern daylight time, June 28, 2025, provided that the Sakalin-2 Byproduct is solely for importation into Japan.

Russia-related GL 113, "Authorizing the Wind Down of Transactions Involving Certain Financial Institutions Blocked on November 21, 2024." Russia-related GL 113 states that all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the wind down of transactions involving the blocked persons listed in Annex to this General License, are authorized through 12:01 a.m. eastern standard time, December 20, 2024, provided that any payment to a blocked person is made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations. 

Finally, OFAC issued Russia-related GL 114, "Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on November 21, 2024."  Russia-related GL 114 states that all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by the following blocked entities to a non-U.S. person are authorized through 12:01 a.m. eastern standard time, December 20, 2024. Such blocked entities are Gazprombank Joint Stock Company and Interstate Bank.

Frequently Asked Questions

In addition to the abovementioned OFAC-issued General Licenses, OFAC has issued two new Russia-related Frequently Asked Questions FAQ 1201, FAQ 1202.  A summary of the Frequently Asked Questions is as follows:

• FAQ 1201.  What authorizations exist for diplomatic or consular missions operating in Russia and Russian diplomatic or consular missions operating abroad?

OFAC has issued several authorizations related to U.S. and third-country diplomatic or consular missions operating in Russia and Russian diplomatic or consular missions operating abroad. This FAQ is broken into three sections as follows:

1. Russian Diplomatic or Consular Missions, Wherever Located:  Russia-related GL 53A authorizes U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation.
    
2. U.S. Diplomatic or Consular Missions in Russia: The Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), authorize all transactions prohibited by the RuHSR that are for the conduct of the official business of the United States Government by employees, grantees, or contractors thereof. 
    
3. Third-Country Diplomatic or Consular Missions in Russia: Russia-related GL 20 authorizes U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in the Russian Federation that are otherwise not permitted.

• FAQ 1202. Following the November 21, 2024 designation of Russian financial institutions, Treasury has now designated a significant number of financial institutions in Russia. Will this negatively impact the processing of personal, non-commercial remittances to or from Russia?

The answer is no, it will not negatively impact the processing of personal, non-commercial remittances to or from Russia. Treasury's sanctions only target Russian financial institutions that have continued to help Russia gain access to the critical goods it needs to prosecute its war in Ukraine, and, as a general matter, personal, non-commercial remittances are not the target of sanctions imposed by the United States on Russia.

Lewis Brisbois’s attorneys are actively engaged in the wide range of legal issues in this area and are advising clients on managing legal and business risk as events continue to develop at an accelerated pace. For more information, contact the author or editor of this alert. Visit our Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice page for additional alerts in this area.

Author:

Joe Magro, Associate

Editor:

Andrew Pidgirsky, Partner and Chair of Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice