We previously discussed sanctions measures that have been enacted in several jurisdictions as a response to the conflict in Ukraine on February 4, February 23, February 25, February 28, and March 3. This post provides an update regarding further Russia-related sanctions measures in the United States.

New General License

On March 3, 2022, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued General License ("GL") 15, which, among other things, authorizes all transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 ("RuHSR"), involving any entity owned 50 percent or more, directly or indirectly, by Alisher Burhanovich Usmanov that is not listed on OFAC's Specially Designated Nationals and Blocked Persons ("SDN") List.

New Designations to OFAC's SDN List

On the same day, OFAC added the following to its SDN List: (i) "numerous Russian elites and their family members"; (ii) "six of their companies"; (iii) "one of Russia's largest privately-owned aircraft"; and (iv) "one of the world's largest superyachts." The OFAC press release is available here.

Additional Guidance and Clarifications

On March 4, 2022, OFAC issued additional guidance related to the sanctions measures previously announced by the U.S. government. In particular, OFAC issued the following new Frequently Asked Questions ("FAQs"):

  • FAQ 1,010 clarifies that companies can continue to transport or sell Russian-origin oil for sale to the United States and/or third countries without violating sanctions pursuant to Executive Order ("E.O.") 14024.
  • FAQ 1,011 states that, in the event a U.S. bank refuses to process a requested payment related to energy despite the authorization in the Russia-related GL 8A under E.O. 14024, persons are encouraged to connect with their financial institution regarding the status of such payment, and that any questions about engaging in or processing transactions related to GL 8A can be directed to OFAC's Sanctions Compliance and Evaluation Division.
  • FAQ 1,012 clarifies that GL 8A authorizes energy-related transactions through 12:01 a.m. eastern daylight time, June 24, 2022, unless renewed, and in the event that GL 8A is not renewed, OFAC intends to issue a general license authorizing the orderly wind down of activities covered by GL 8A.

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