On May 25, 2022, the US Department of the Treasury’s Office of Foreign Assets Control issued Russia-related General License 13A, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024” (“GL 13A”), which amends and replaces the former GL 13.  Our previous blog post on GL 13 can be found here.

Consistent with GL 13, GL 13A 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. 

GL 13A was amended to state that the above-described authorizations apply to “entities owned or controlled, directly or indirectly, by a US person.”  This appears to clarify that GL 13A authorizes US Person involvement in activities covered by GL 13A (e.g., payment of import duties) that are conducted by non-US subsidiaries of US Persons.

The authorization of GL 13A was also extended through 12:01 a.m. Eastern time on September 30, 2022. 

The authors acknowledge 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.


Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.