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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On March 24, 2022, the Office of Foreign Assets Control (OFAC) issued two amended general licenses (GL) and two new GLs involving Russia-related sanctions programs. OFAC has also updated its <a href="https://home.treasury.gov/policy-issues/financial-sanctions/faqs/updated/2022-03-24" target="_blank" rel="noopener">FAQs 1,023 and 1,024</a> to reflect the changes in GL 17A.
<ul>
<li>General License 6A: <a href="https://home.treasury.gov/system/files/126/russia_gl6a.pdf" target="_blank" rel="noopener">GL 6</a> authorized transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations that are ordinarily incident and necessary to, among other things, the exportation or reexportation of agricultural commodities, medicine and medical devices to, from, or transiting Russia. Amended GL 6A contains an additional subsection that clarifies that any debit to an account of a U.S. 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, or any transaction otherwise prohibited by EOs 14066 or 14068, are not authorized by GL 6A.</li>
<li>General License 17A: The original GL 17, which expired on March 25, 2022, authorized transactions ordinarily incident and necessary to the importation of certain Russian-origin items otherwise prohibited by EO 14068 pursuant to contracts entered into prior to March 11, 2022. Amended <a href="https://home.treasury.gov/system/files/126/russia_gl17a.pdf" target="_blank" rel="noopener">GL 17A</a> extends this authorization for Russian-origin seafood pursuant to contracts entered into prior to March 11, 2022 until June 23, 2022.</li>
<li>General License 20: <a href="https://home.treasury.gov/system/files/126/russia_gl20.pdf" target="_blank" rel="noopener">GL 20</a> authorizes U.S. persons to engage in transactions ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in Russia that are otherwise prohibited by EOs 14024 and 14068, which prohibits direct or indirect supply of U.S. dollar-denominated banknotes to the government of Russia or any person located in Russia.</li>
<li>General License 25: <a href="https://home.treasury.gov/system/files/126/ukraine_gl25.pdf" target="_blank" rel="noopener">GL 25</a> under the Ukraine-related sanctions authorizes journalistic activities and the establishment of news bureaus in the Crimean region and the so-called Donetsk People&rsquo;s Republic (DNR) and Luhansk People&rsquo;s Republic (LNR) regions of Ukraine.</li>
</ul>

OFAC Issues New Russia-Related General Licenses

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