On September 4, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia General License (GL) 25E that continues to authorize all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. This continues to allow for services incident to the exchange of communications over the internet, such as instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming, e-learning platforms, automated translation, web maps, user authentication services, web hosting, and domain name registration services. 

The GL also allows for the export or reexport of software, hardware, or technology incident to the exchange of communications over the internet so long as it is licensed or otherwise authorized by the Department of Commerce under the Export Administration Regulations. However, certain dealings – including transactions involving significant Russian telecommunications companies that have been designated by OFAC and placed on the Specially Designated Nationals and Blocked Persons List – continue to remain unauthorized under this GL and therefore require close analysis. OFAC has amended Russia-related Frequently Asked Question 1040 addressing this GL as well.

Additionally, OFAC has published an alert, “Russian Attempts to Evade Sanctions Using New Overseas Branches and Subsidiaries,” to warn foreign jurisdictions and financial institutions about Russia’s attempts to evade sanctions by opening new overseas branches and subsidiaries of Russian financial institutions. The alert notes that “efforts to open new branches or subsidiaries of Russia financial institutions should be viewed as a red flag for attempted Russian sanctions evasion.” As such, foreign regulators and financial institutions are cautioned that “deal[ing] with such branches or subsidiaries — including activities such as maintaining accounts, transferring funds, or providing other financial services such as payment processing, trade finance, and insurance — should be aware of the significant sanctions risks associated with facilitating Russia’s efforts to evade sanctions.”