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, and here. The content of the two GLs is summarized below.

GL 38A

As explained in detail in our prior blog post, GL 38 authorizes all transactions ordinarily incident and necessary to the processing of pension payments to US Persons to the extent otherwise prohibited by Executive Order (“EO”) 14024. The only substantive change made by GL 38A to GL 38 is that GL 38A expanded the authorization under GL 38 to also cover transactions related to the processing of pension payments to non-US persons outside of Russia. This expanded authorization is subject to the same conditions and limitations prescribed in GL 38.

GL 50

GL 50 authorizes all transactions that are ordinarily incident and necessary to (1) the closing of a non-blocked/non-SDN individual’s account at a financial institution blocked pursuant to EO 14024 and (2) the unblocking and lump sum transfer of all remaining funds and other assets in the closed account to the non-blocked/non-SDN individual, including to the non-blocked/non-SDN individual’s other account at a non-blocked/non-SDN financial institution. GL 50 specifically excludes certain transactions from the scope of the authorization, such as the opening or maintaining of a correspondent or payable-through account for or on behalf of any entity subject to Directive 2 under EO 14024 or transactions prohibited by Directive 4 under EO14024.


Mr. McMillan's practice involves compliance counseling; compliance programs; licensing; compliance reviews; internal investigations; voluntary disclosures; administrative enforcement actions; criminal investigations; customs inquiries, audits, detentions, and seizures; and trade-compliance due diligence and post-acquisition integration in mergers and acquisitions. His practice includes matters that implicate the US International Traffic in Arms Regulations (ITAR), US Export Administration Regulations (EAR), US National Industrial Security Program (NISP), the US Committee on Foreign Investment in the United States (CFIUS), and equivalent non-US laws. Mr. McMillan regularly advises on and represents clients in matters involving technology, including its control, protection, accidental disclosure, diversion, or unauthorized collection. Mr. McMillan has extensive experience working with companies in the aerospace and defense industry, as well as companies in the Middle East and other parts of Asia.


Alex advises clients on compliance with US export controls, trade and economic sanctions, export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and antiboycott controls. He counsels on and prepares filings to submit to the US Government's Committee on Foreign Investment in the United States (CFIUS) with respect to the acquisition of US enterprises by non-US interests. Moreover, Alex advises US and non-US companies in the context of licensing, enforcement actions, internal investigations, compliance audits, mergers and acquisitions and other cross-border transactions, and the design, implementation, and administration of compliance programs. He has negotiated enforcement settlements related to both US sanctions and the EAR.


Iris's practice involves assisting multinational companies with a wide range of trade matters including export controls, sanctions, internal investigations and risk assessments. She also assists companies with respect to customs laws and other trade regulation issues in the US and abroad. Iris's practice extends to assistance in internal compliance reviews as well as enforcement actions and disclosures necessitated by US government action.