The US Department of the Treasury’s Office of Foreign Assets Control recently issued General License 8H pursuant to Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587, to extend the authorization of energy-related transactions to May 1, 2024 for transactions that would otherwise be prohibited by Executive Order 14024 but involve one or more of the following entities:
• State Corporation Bank for Development and Foreign Economic Affairs Vnesheconomank;
• Public Joint Stock Company Bank Financial Corporation Otkritie;
• Sovcombank Open Joint Stock Company;
• Public Joint Stock Company Sberbank of Russia;
• VTB Bank Public Joint Stock Company;
• Joint Stock Company Alfa-Bank;
• Public Joint Stock Company Rosbank;
• Bank Zenit Public Joint Stock Company;
• Bank Saint-Petersburg Public Joint Stock Company;
• Entities in which one or more of the abovementioned persons own a 50 percent or greater interest; or
• The Central Bank of the Russian Federation.
GL 8H effectively replaces and supersedes GL 8G in its entirety.