On January 17, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three amended General Licenses (GLs) regarding the continued authorization of certain limited activities in Russia or involving Russian entities.
- Russia-related General License 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials.” Revised GL 6C has added the term “provision” to the described authorized transactions so that the text in the authorizing first paragraph now reads: “(1) the production, manufacturing, sale, transport, or provision of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices.” The revision also removed text that previously authorized certain accounting, trust, corporate and management services and activities as the deadline under separate authorization for such activities has now passed. For past information on this GL and OFAC’s Fact Sheet offering clarity on agricultural commodities, equipment, and medicine, see Update of July 15, 2022.
- Russia-related General License 54A, “Authorizing Certain Transactions Involving VEON Ltd. or VEON Holdings B.V. Prohibited by Executive Order 14071.” This GL authorizes all transactions ordinarily incident and necessary to the purchase or receipt of any debt or equity securities of VEON Ltd. or VEON Holdings B.V. that would otherwise be prohibited under section 1(a)(i) of Executive Order 14071, provided that such debt or equity securities were issued prior to June 6, 2022. The revision adds VEON Holdings B.V., which is ultimate 100% owned by VEON Ltd. Several Russian individuals sanctioned by the U.S., United Kingdom and European Union are minority owners in VEON’s corporate structure.
- Russia-related General License 28B, “Authorizing the Wind Down and Rejection of Certain Transactions Involving Public Joint Stock Company Transkapitalbank and Afghanistan.” Revised GL 28B extends until March 18, 2023, authorization to continue transactions ordinarily incident and necessary to wind down transactions involving PJSC Transkapitalbank (TKB), or any entity in which TKB owns, directly or indirectly, a 50% or greater interest, that are ultimately destined for or originating from Afghanistan and otherwise prohibited by E.O. 14024.
Certain transactions remain unauthorized under these general licenses and therefore require close analysis.