The Office of Foreign Assets Control (OFAC) has issued several authorizations related to U.S. and third-country diplomatic or consular missions operating in Russia and Russian diplomatic or consular missions operating abroad.
Russian Diplomatic or Consular Missions, Wherever Located: Russia-related General License (GL) 53A authorizes, subject to certain conditions, 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 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."
U.S. Diplomatic or Consular Missions in Russia: The Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), authorize all transactions prohibited by the RuHSR that are for the conduct of the official business of the United States Government by employees, grantees, or contractors thereof. (See § 587.509). This authorization extends to the official business of U.S. diplomatic or consular missions. Additionally, E.O. 14024 exempts transactions for the official business of the United States Government conducted by its employees, grantees, and contractors from the prohibitions of the order.
Third-Country Diplomatic or Consular Missions in Russia: Russia-related GL 20 authorizes, subject to certain conditions, U.S. persons to engage in all transactions ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in the Russian Federation that are prohibited by E.O. 14024 or section 1(a)(iv) of E.O. 14068.
As a general matter, transactions that are "ordinarily incident and necessary" to the official business of a diplomatic or consular mission, whether third-country or Russian, include standard foreign diplomatic or consular mission operations, including bank transactions related to the operation of those missions, such as salary payments, expense reimbursement for employees, or payments of utilities for diplomatic or consular facilities.