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1096. Do U.S. sanctions prohibit U.S. persons from engaging in transactions that are ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation located in or outside the United States?

Answer

OFAC issued Russia-related General License (GL) 53A to authorize U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions of the Government of the Russian Federation ("Russian missions"), where the transactions are prohibited by Executive Order (E.O.) 14024 and involve Gazprombank, or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, or are prohibited by Directive 4 under E.O. 14024, "Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation." This authorization applies to transactions related to Russian missions located in or outside the United States. For example, GL 53A authorizes the payment of salaries to employees of Russian missions that may otherwise be prohibited by Directive 4, such as a payment originated by the Ministry of Finance of the Russian Federation from a non-blocked Russian bank. GL 53A also authorizes the payment of salaries to employees of Russian missions that may otherwise be prohibited due to the involvement of Gazprombank. Non-U.S. persons may engage in transactions that are authorized for U.S. persons under this GL without risk of sanctions under E.O. 14024.

Importantly, GL 53A does not authorize any transactions involving blocked persons other than Gazprombank, including blocked Russian financial institutions, nor does it authorize debits to the accounts on the books of U.S. financial institutions of entities subject to Directive 4.

Date Updated: November 21, 2024

Date Released
November 10, 2022