On April 19, 2022, the US Department of the Treasury’s Office of Foreign Assets Control issued the “Fact Sheet: Preserving Agricultural Trade, Access to Communication and Other Support to Those Impacted by Russia’s War against Ukraine” to provide the public with guidance on the many humanitarian and food-related authorizations issued by OFAC in an effort to facilitate support for people impacted by Russia’s war with Ukraine. The guidance was issued following the “Tackling Food Insecurity: The Challenge and Call to Action” event held by Treasury Secretary Janet Yellen to address the rising threat of global food insecurity that has been exacerbated by Russia’s war at a time when certain emerging markets and developing countries continue to struggle to recover from the COVID-19 pandemic and supply chain issues for agricultural goods have driven up food and energy costs. The fact sheet is intended to provide financial institutions, non-governmental organizations (NGOs), and market participants with information to help them easily determine whether certain transactions, including those related to agriculture commodities, telecommunications or internet-based communications, and emergency medical services, among others, are authorized by OFAC or exempt altogether. The fact sheet also includes a discussion on the new Russia-related General License 27 that was issued by OFAC earlier in the day.
General License 27 was issued by OFAC pursuant to Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), 31 CFR part 587, to authorize transactions by NGOs that would otherwise be prohibited by the RuHSR, provided that the only blocked persons involved in a transaction are processing funds by financial institutions that were blocked pursuant to EO 14024. Activities that are authorized by GL 27 include: 1) humanitarian projects that meet basic human needs in Ukraine or Russia including drought/flood relief and provision of food/medicine to vulnerable populations; 2) projects that support democracy building in Ukraine or Russia; 3) programs that support education in Ukraine or Russia; 4) non-commercial development projects that directly benefit the people of Ukraine or Russia including health, water and sanitation; and 5) projects that support environmental and natural resource protection in Ukraine or Russia, including the preservation of threatened or endangered species and the remediation of pollution or other environmental damage. Among the activities that are not authorized are those prohibited by Directive 2 under EO 14024 or transactions prohibited by EO 14066 or EO 14068.