On September 13, 2024, the United States designated and placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List three entities and two individuals for their connection to Russia’s destabilizing actions abroad, particularly efforts to undermine and manipulate the outcome of the October 2024 Moldovan presidential election. Two of the entities are Russian state-owned and state-funded broadcast agencies that control the RT (formerly “Russia Today”) media channel, and the third Russian entity has been designated for attempting to move money into Moldova in an effort to influence the upcoming election. For additional identifying details on the involved individuals, entities see here.
As a result, all property and interests in property of the designated persons and entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.
Related General Licenses
Related to these designations, OFAC issued Russia-related General License (GL) 109, “Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on September 13, 2024.” This GL is effective as of September 13, 2024, and authorizes all transactions that are ordinarily incident and necessary to the wind down of any transaction involving the following blocked entities:
- Federal State Unitary Enterprise International Information Agency Rossiya Segodnya.
- Autonomous Non Profit Organization TV Novosti.
- Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50% or greater interest.
These transactions are authorized through 12:01 a.m. Eastern Standard Time, November 13, 2024. Any payment to a blocked person must be made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587.
Certain transactions remain unauthorized under this GL and therefore require close analysis.
OFAC also issued an updated GL 25F, “Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications,” which supersedes GL 25E dated September 4, 2024, making it the current applicable GL. The primary difference between GL 25F and GL 25E is the expansion of the list of entities excluded from the GL to add Federal State Unitary Enterprise International Information Agency Rossiya Segodnya and Autonomous Non-Profit Organization TV Novosti. OFAC also published an updated, Russia-related Frequently Asked Question (FAQ 1040) addressing this GL. See our previous publication regarding GL 25 dated September 6, 2024.