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 expire on September 30, 2022. 

GL 13B 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 post on GL 13A can be found 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.


Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.