The Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued several Russia-related general licenses under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. Part 587 (RuHSR). These licenses authorize certain activities which would otherwise be prohibited under OFAC sanctions toward Russia:
GL 26A extends until July 12, 2022 existing authorizations for transactions ordinarily incident and necessary to wind down transactions involving Joint Stock Company SB Sberbank Kazakhstan, Sberbank Europe AG, or Sberbank (Switzerland) AG, and supersedes and replaces GL 26. The general license also applies to transactions with entities owned 50% or greater by these Sberbank entities. This license does not authorize: (1) opening/maintaining Correspondent or Payable-Through Accounts (CAPTA) for entities subject to Directive 2 of Executive Order 14024; (2) transactions with the Central Bank of the Russian Federation (CBR), the National Wealth Fund of the Russian Federation (NWF), and the Ministry of Finance of the Russian Federation (MoF); and (3) transactions with other OFAC-blocked persons.
GL 30 authorizes transactions involving Gazprom Germania GmbH (and any entities owned 50% or greater by this entity) that are prohibited by Directive 3 under Executive Order 14024 regarding the provision of new debt or new equity to certain Russian entities until September 30, 2022. This license does not authorize transactions with other OFAC-blocked persons. Directive 3 applies to certain Gazprom entities, but in early April 2022, Gazprom announced that it was relinquishing its business interests and assets in Gazprom Germania GmbH. German regulatory authorities subsequently took control of the company to ensure its continued operations.
GL 32 authorizes transactions ordinarily incident and necessary to wind down transactions involving OFAC-sanctioned Amsterdam Trade Bank NV (and any entities owned 50% or greater by this entity) until July 12, 2022. This license does not authorize: (1) opening/maintaining CAPTA for entities subject to Directive 2 of Executive Order 14024; (2) transactions with the CBR, NWF or MoF; and (3) transactions with other OFAC-blocked persons.