On May 5, 2022, the Department of the Treasury’s Office of Foreign Assets Control issued four Russia-related general licenses in an effort to authorize activities that are otherwise prohibited by the Russia Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587. The general licenses authorize payments and services in connection with overflights or emergency landings associated with the Russian Federation (GL 7A); extend wind down transactions involving Joint Stock Company SB Sberbank Kazakhstan, Sberbank Europe AG, or Sberbank (Switzerland) AG (GL 26A) and Amsterdam Trade Bank NV (GL 32) until July 12, 2022; and authorize certain transactions related to patents, trademarks and copyrights in the US or Russian Federation (GL 31).
OFAC also issued new Frequently Asked Question 1032 to address the designation of Transkapitalbank (TKB) and clarify the types of Afghanistan-related transactions that US persons can temporarily engage in with TKB under Russia-related GL 28 and 29.
Finally, OFAC also amended FAQ 1009 to make clear to US persons that Executive Order 14065, which targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine, does not block the entire Donetsk and Luhansk oblasts, but only prohibits certain transactions within “Covered Regions” in Ukraine. OFAC urges US persons to see FAQ 1006 for more information on the prohibitions that apply to these Covered Regions.