On November 10, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) reissued Russia-related General License 8D, “Authorizing Transactions Related to Energy.”  The scope of the General License did not change since the previous reissuance; however, transactions “related to energy” with the list of entities listed in the General License are now authorized through 12:01 a.m. eastern standard time, May 15, 2023.   

General License 8D authorizes transactions “related to energy” with: (i) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (i.e., “VEB Bank”); (ii) Otkritie; (iii) Sovcombank; (iv) Sberbank; (v) VTB Bank; (vi) Joint Stock Company Alfa-Bank; and (vii) the Central Bank of the Russian Federation; and any entity in which is owned 50% or more.  Our blog post on the initial issuance of this General License can be found here.  Our blog posts on the previous reissuances of this General License can be found herehere, and 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.