1198. In light of the designation of Shreya Life Sciences Private Limited (Shreya), are U.S. persons authorized to engage in transactions related to pharmaceutical and other humanitarian-related goods involving Shreya and its subsidiaries?

Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions.

OFAC has issued Russia-related General License (GL) 6D, which authorizes, among other things, certain transactions related to the production, manufacturing, sale, transport, or provision of medicine and medical devices. U.S. persons may continue to engage in authorized transactions involving Shreya under GL 6D. Additionally, non-U.S. persons generally would not face sanctions risk for engaging in transactions authorized for U.S. persons under general licenses issued pursuant to the Russian Harmful Foreign Activities Sanctions program. For further information, please review the OFAC Food Security Fact Sheet: Russia Sanctions and Agricultural Trade.