Russia-related GL 6C (“Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials”) remains valid and authorizes, among other things, certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, ordinarily incident and necessary to (1) the production, manufacturing, sale, transport, or provision of agricultural commodities, including products such as fish, seafood, or preparations thereof — to the extent they fall within the definition of agricultural commodities provided in GL 6C — to, from, or transiting the Russian Federation (see FAQ 979).
However, GL 6C does not authorize any transactions prohibited by E.O. 14068, including transactions prohibited by the determination of December 22, 2023 (Seafood Determination). In particular, E.O. 14068 prohibits the importation into the United States of, among other things, Russian Federation origin fish, seafood, and preparations thereof. The Seafood Determination further prohibits the importation of salmon, cod, pollock, or crab produced wholly or in part in the Russian Federation, or harvested in waters under the jurisdiction of the Russian Federation or by Russia-flagged vessels, notwithstanding whether such salmon, cod, pollock, or crab has been incorporated or substantially transformed into another product outside of the Russian Federation. As such, U.S. persons cannot rely on GL 6C for transactions that are for the importation into the United States of Russian Federation origin fish, seafood, or preparations thereof, or salmon, cod, pollock, or crab covered by the Seafood Determination, unless otherwise authorized by OFAC. However, U.S. persons may continue to rely on GL 6C for transactions otherwise prohibited by E.O. 14024 involving agricultural commodities.
Date Updated: February 23, 2024