On June 28, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) and the Office of Financial Sanctions Implementation of the HM Treasury (“OFSI“) jointly issued a Humanitarian Assistance and Food Security Fact Sheet (the “Fact Sheet”) to provide additional clarity on US and UK Russia-related sanctions in the context of humanitarian assistance and the export to Russia of agricultural commodities, medicines, and medical devices.
The Fact Sheet provides US and UK responses to the following questions:
- Do US and UK sanctions targeting Russia provide exceptions for non-government organizations (“NGOs”) or international organizations (“IOs”) providing humanitarian assistance?
- In sum, the FACT Sheet notes that both the US and the UK have issued one or more general licenses (“GLs”) related to such activities, and both countries prioritize applications for specific licenses related to humanitarian activities.
- Can US and UK financial institutions process transactions related to the exportation of agricultural commodities, medicine, or medical devices to, from, transiting, or related to Russia?
- In sum, the FACT Sheet confirms that to generally be the case.
- Can US and UK financial institutions process transactions involving Joint Stock Company Russian Agricultural Bank (Russian Agricultural Bank) related to the exportation of agricultural commodities to, from, transiting, or related to Russia?
- In sum, the Fact Sheet confirms that to be case subject to certain conditions.
The Fact Sheet also includes links to various humanitarian GLs, guidance and FAQs previously published by the US and UK.
This is the first Fact Sheet published jointly by OFAC and OFSI and is an indicator of the increased cooperation between US and UK sanctions authorities following the joint publication by the two authorities last October on enhanced partnership. OFAC and OFSI stated that they will continue to work together to ensure that sanctions do not prevent humanitarian trade and assistance from reaching those in need.
