On November 21, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia-related General License (GL) 13C, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by Directive 4, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation. Directive 4 prohibits any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.
The only revision to this GL is the extension of time for such authorizations. Originally set to expire on December 7, the effectiveness of this GL has been extended through 12:01 a.m. eastern standard time, March 7, 2023. Certain dealings remain unauthorized under this general license and therefore require close analysis.