On November 10, 2022, the Department of the Treasury’s Office of Foreign Assets Control issued General License 53 pursuant to the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587; OFAC also issued Frequently Asked Question 1096 to clarify the operation of GL 53. The general license authorizes all transactions involving diplomatic or consular missions of the Government of the Russian Federation (“Russian missions”) that would otherwise be prohibited by Directive 4 under Executive Order 14024. This includes transactions related to the compensation of employees of Russian missions, including salary payments and expense reimbursements that would otherwise be prohibited by Directive 4 under EO 14024.
FAQ 1096 clarifies that the authorization in GL 53 applies to all transactions related to Russian missions, both inside and outside of the US, as long as the transactions do not involve blocked persons and do not involve debits to accounts on the books of US financial institutions of entities subject to Directive 4. In addition, non-US persons are permitted to engage in any transaction that US persons are authorized to engage in under GL 53, without the risk of sanctions under EO 14024.