On May 2 and 5, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three new and two amended Russia-related General Licenses (“GLs”).  OFAC also issued one new Frequently Asked Question (“FAQ”) and amended another.  Additionally, Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a tranche of Russia-related FAQs. 

New General Licenses

  • GL 30 authorizes all transactions involving Gazprom Germania GmbH that are prohibited by Directive 3 under Executive Order (EO) 14024, including transactions involving any entity in which Gazprom Germania GmbH owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m., eastern daylight time, September 30, 2022.  Directive 3, which was issued on February 24, 2022, restricts new debt and equity of certain specified Russian parties. 
  • GL 31 authorizes the filing, receipt, renewal or maintenance, and prosecution of patents, trademarks, copyrights, or other forms of intellectual property protection in the United States or Russia prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587.
  • GL 32 authorizes all transactions ordinarily incident and necessary to the wind down of transactions involving Amsterdam Trade Bank NV, or any entity in which Amsterdam Trade Bank NV owns, directly or indirectly, a 50 percent or greater interest, which are prohibited by EO 14024, through 12:01 a.m. eastern daylight time, July 12, 2022.

Amended General Licenses

  • GL 7A, which authorizes certain transactions related to overflight payments, emergency landings, and air ambulance services, was amended to clarify that the general license does not authorize any debit to an account on the books of a US financial institution of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. 
  • GL 26A was amended to add Sberbank (Switzerland) AG to the existing authority to engage in all transactions ordinarily incident and necessary to the wind down of transactions involving Joint Stock Company SB Sberbank Kazakhstan and Sberbank Europe AG, or any entity in which they hold, directly or indirectly, a 50 perfect or greater interest, through 12:01 am ET, July 12, 2022. 

New and Amended OFAC Frequently Asked Questions

In conjunction with the above GLs, OFAC issued one new FAQ and reissued another.

The new FAQ 1,032 clarifies that US persons and US financial institutions are authorized to continue to engage in certain transactions with Public Joint Stock Company Transkapitalbank (“TKB”), or any entity in which TKB owns, directly or indirectly, a 50 percent or greater interest, in reliance on Russia-related GL 28 through 12:01 a.m. eastern daylight time, October 20, 2022 or in reliance on GL 29.  Our previous blog post covering these GLs can be found here.

The amended FAQ 1,009 advises that US persons may reasonable rely on vetted information from reliable third parties, such as postal codes and maps, when determining whether a location is within the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) regions of Ukraine that are blocked by EO 14065 (collectively referred to as the “Covered Regions”).  Our previous blog post on comprehensive sanctions targeting the DNR and LNR can be found here.

New BIS Frequently Asked Questions

On May 2, 2022, BIS issued a tranche of Russia-related FAQs covering license requirements, license application review policies, foreign direct product and de minimis rules, excluded countries, luxury goods, license exceptions and country group and country chart changes.  These FAQs come a few weeks after BIS expanded license requirements for Russia and Belarus under the Export Administration Regulations (“EAR”) to all items on the Commerce Control List (“CCL”).  Our blog post on the expanded license requirements can be found here

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


Mr. Coward focuses on outbound trade compliance matters, including the extraterritorial application of US law, particularly US export control laws, anti-boycott regulations and trade sanctions/embargoes maintained by the US government against various countries. In addition, his practice covers issues of corporate conduct such as the application of the Foreign Corrupt Practices Act and foreign bribery laws. He provides international transactional advice; assistance in the design and implementation of corporate compliance programs, compliance audits, and internal investigations; and representation in enforcement proceedings.


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.