On January 30, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued three Ukraine-related general licenses authorizing certain transactions relating to Crimea that would otherwise be prohibited under Executive Order 13685.  As detailed in our recent post, Executive Order 13685 imposed comprehensive sanctions on the Crimea region of Ukraine and provided the authority for blocking certain persons in connection with the situation in Crimea.  Consistent with Executive Order 13685, the US Government also recently imposed a license requirement on the export, reexport, or transfer by any person of virtually all items subject to the Export Administration Regulations to or within Crimea, as we detailed previously here.  OFAC’s announcement regarding the publication of General License No. 6, General License No. 7 and General License No. 8 is available here.

General License No. 6 – Noncommercial, Personal Remittances Authorized

General License No. 6 authorizes US Persons to send and receive funds to or from Crimea, or for or on behalf of an individual ordinarily resident in Crimea, where the transfer involves a noncommercial, personal remittance.  General License No. 6 also authorizes US depository institutions, registered brokers or dealers in securities, and registered money transmitters to process such transfers.  In addition, General License No. 6 authorizes US Person individuals to carry funds as a noncommercial, personal remittance to an individual in Crimea or to an individual ordinarily resident in Crimea.

The use of General License No. 6 is subject to certain conditions, including a prohibition on transactions involving Specially Designated Nationals (“SDNs”).

General License No. 7 – Operation of Accounts Authorize

General License No. 7 authorizes the operation of an account in a US financial institution for an individual ordinarily resident in Crimea provided that transactions processed through the account:

  1. are of a personal nature and not for use in supporting or operating a business; and
  2. do not involve transfers directly or indirectly to Crimea or for the benefit of individuals ordinarily resident in Crimea (except transfers of noncommercial, personal remittances as authorized by General License No. 6).

The use of General License No. 7 is also subject to certain conditions, including a prohibition on the operation of such accounts for SDNs.

General License No. 8 – Transactions Related to Telecommunications and Mail Authorized

General License No. 8 authorizes all transactions with respect to the receipt and transmission of telecommunications involving Crimea, provided that no payments involve any transactions with SDNs.  (The general license does not authorize the provision, sale, or lease of (i) telecommunications equipment or technology or (ii) capacity on telecommunications transmission facilities (e.g., satellite or terrestrial network activity).)

General License No. 8 also authorizes all transactions of common carriers incident to the receipt or transmission of mail and packages between the United States and Crimea, provided that the importation or exportation of such mail and packages is otherwise permissible under the Ukraine-related sanctions.


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.


Kathryn Anderson is an associate in Baker McKenzie's International Commercial Practice Group in San Francisco. Kathryn's practice focuses on cross-border transactions and international trade regulation, including export controls, trade and investment sanctions, anti-terrorism controls, and customs and import regulations. Her practice also covers anti-corruption rules and international corporate compliance.

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