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OFAC

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On September 15, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued (i) two new Determinations under Executive Order (“EO”) 14024; (ii) two new Russia-related General Licenses (“GLs”); (iii) seven new Frequently Asked Questions (“FAQs”) and (iv) five amended FAQs. A press release was issued in tandem with these actions. New Determinations under EO 14024 The new Determination Pursuant to Section 1(a)(i) of Executive Order 14024 expands authorities for the…

Following the G7 Finance Ministers Meeting on September 2, 2022 (see our previous blog here), on September 9, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued preliminary guidance on implementation of the policy banning the provision of services related to the maritime transportation of (i) Russian-origin crude oil and (ii) Russian-origin petroleum products (together “seaborne Russian oil”) (the “Maritime Services Policy”).  The ban under the Maritime Services Policy will…

On September 8, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued Russia-related General License 13B, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024” (“GL 13B”), which amends and replaces the former GL 13A. The authorization of GL 13B is extended through 12:01 a.m. Eastern time on December 7, 2022.  This is the second time an extension has been granted.  GL 13A was previously set to…

On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) replaced existing General License (“GL”) 38 with GL 38A and issued a new GL 50. These GLs authorize certain activities otherwise prohibited by EO 14024, which targets, among other things, specific sectors (including the financial services sector) of the Russian economy. Our prior blog post regarding EO 14024 and the financial sanctions imposed thereunder can be found here, here, here,…