On May 2, 2022, new amendments to the Ukraine Related Sanctions Regulations, renaming them “Ukraine-/Russia-Related Sanctions Regulations” (URSR), were published by U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) in the Federal Register. The Ukraine-/Russia-Related Sanctions Regulations went into effect May 2.
OFAC’s new URSR replace the Ukraine Related Sanctions Regulations that were published in abbreviated form on May 8, 2014 with a more comprehensive set of regulations that includes additional interpretative and definitional guidance, general licenses, and other regulatory provisions that will provide further guidance. The revised regulations implement provisions of several statutes related to Ukraine as well as Executive Order 13685.
OFAC also added seven new general licenses which generally authorize certain transactions relating to investment and reinvestment of funds, official business of the U.S. government, and official business of certain international organizations. Specifically, new sections 589.509, 589.510 and 589.511 incorporate general licenses authorizing certain transactions relating to investment and reinvestment of funds, official business of the U.S. government, and official business of certain international organizations and entities. New sections 589.518, 589.519 and 589.520 authorize activities specific to the Crimea region of Ukraine: “Transactions necessary and ordinarily incident to publishing, emergency landings and air ambulance services, and the export of certain services in support of nongovernmental organizations’ activities.” New section 589.521 authorizes transactions related to closing a correspondent or payable-through account. OFAC noted in the final rule that the “addition of these general licenses to the Regulations do not represent a significant alteration of the United States’ foreign policy with regard to the Russian Federation.”
Additionally, OFAC also announced that it is revising several FAQs for the Ukraine-/Russia-Related Sanctions Regulations to reflect these changes.