On July 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued three Russia-related General Licenses (“GLs”) and issued one new one.  OFAC also amended FAQs 967, 1,039, and 1,040, with changes mostly relating to updates made within the GLs.  OFAC also issued a new fact sheet on “Russia Sanctions and Agricultural Trade.”

GL 6B was amended to broaden the scope of authorized activities in three ways: (i) to broaden the type of authorized transactions to those “ordinarily incident and necessary to” the listed activities to transactions “related to” the listed activities; and (iii) to also apply to agricultural equipment. (ii) to broaden the authorization from only authorizing exports/imports of eligible agricultural commodities, medicines, and medical devices to/from Russia to production, manufacturing, sale, and transport of such products. GL 6B expressly notes that it does not authorize activities prohibited by Executive Order 14071, which includes the prohibitions on new investments and the provision of accounting, trust and corporate formation, and management consulting services.

GL 25C was amended to include (i) New Eastern Outlook; and (ii) Oriental Review to the list of companies excluded from the scope of GL 25C.  GL 25C authorizes certain transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation.

GL 30A was amended to authorize certain transactions with SEFE Securing Energy for Europe GmbH.  This entity was formerly known as Gazprom Germania GmbH, and GL 30A was reissued to reflect that change.  These transactions are now authorized through 12:01 a.m. EST on December 16, 2022. 

The new GL 44 authorizes certain accounting services to US individuals located in the Russian Federation.  Specifically, GL 44 refers to “tax preparation or filing services to any individual who is a United States person located in the Russian Federation.”

OFAC issued the food-security related fact sheet “Russia Sanctions and Agricultural Trade” in tandem with the new and amended GLs and FAQs.  The fact sheet confirms that US sanctions do not prohibit the exportation of agricultural commodities from, to, transiting, or related to the Russian Federation.  The fact sheet references GL 6B throughout regarding transactions involving insurance and reinsurance services, transaction processing by US financial institutions, and transactions involving Joint Stock Company Russian Agricultural Bank. 

The authors acknowledge the assistance of Ryan Orange with the preparation of this blog post. 


Paul Amberg is a partner in Baker McKenzie’s Madrid office, where he handles international trade and compliance issues. He advises multinational companies on export controls, trade sanctions, antiboycott rules, customs laws, anticorruption laws, and commercial law matters. Paul helps clients assess and address compliance risks presented by export controls, trade sanctions, antiboycott rules, customs laws, and anticorruption laws. His practice especially focuses on internal reviews, voluntary disclosure filings, and enforcement actions brought by, the US Government in relation to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), trade and economic sanctions programs, and US customs laws.


Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.