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. 

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.