On November 21, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued Russia-related General License 13C, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024” (“GL 13B”), which amends and replaces the former GL 13B. The authorization of GL 13C is extended through 12:01 a.m. Eastern time on March 7, 2023.  This is the third time an extension has been granted.  GL 13B was previously set to expire on December 7, 2022. 

GL 13C continues to authorize, subject to certain conditions, US Persons to pay taxes, fees, or import duties and to purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions would otherwise be prohibited on the basis that they involve the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of Russia, and provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in Russia. 

Our previous blog posts on GL 13B and 13A can be found here and here.  Our blog post on the original GL 13 can be found here.

The author acknowledges the assistance of Ryan Orange with the preparation of this blog post.


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.