On January 10, 2025, OFAC issued amended General License (GL) 8L to authorize the wind-down of transactions related to energy involving certain Russian financial institutions sanctioned pursuant to E.O. 14024 through 12:01 a.m. eastern daylight time, March 12, 2025. GL 8L authorizes certain transactions "related to energy" (as defined in the GL; see also FAQ 977) involving the following entities (collectively, "Covered Entities"):
- State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB);
- Public Joint Stock Company Bank Financial Corporation Otkritie;
- Sovcombank Open Joint Stock Company;
- Public Joint Stock Company Sberbank of Russia;
- VTB Bank Public Joint Stock Company;
- Joint Stock Company Alfa-Bank;
- Public Joint Stock Company Rosbank;
- Bank Zenit Public Joint Stock Company;
- Bank Saint-Petersburg Public Joint Stock Company;
- National Clearing Center (NCC);
- Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above entities; and
- The Central Bank of the Russian Federation.
GL 8L does not authorize any transaction prohibited by Directive 1A under E.O. 14024, "Prohibitions Related to Certain Sovereign Debt of the Russian Federation" (Russia-related Sovereign Debt Directive). In addition, GL 8L does not authorize any debit to an account on the books of a U.S. financial institution of the Central Bank of the Russian Federation. Further, GL 8L does not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of foreign financial institutions subject to the prohibitions of Directive 2 under E.O. 14024, "Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions" (the "Russia-related CAPTA Directive"). Consequently, in order for a U.S. financial institution to engage in transactions authorized by GL 8L, all funds transfers related to energy involving one or more Covered Entities must be processed indirectly through a non-sanctioned, non-U.S. financial institution. Please see FAQ 978 for examples of authorized and prohibited transactions flows under certain GLs, including GL 8L.
For purposes of assessing whether certain transactions are authorized under GL 8L, U.S. persons may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided by the parties thereto.
GL 8L is valid until 12:01 eastern daylight time, March 12, 2025. Persons unable to wind down prohibited transactions with the Covered Entities by March 12, 2025 are encouraged to approach the Office of Foreign Assets Control.
GL 8L provides authorization solely under E.O. 14024. Therefore, U.S. financial institutions that rely on the authorization provided in GL 8L to process transactions related to energy must also comply with the prohibitions of E.O. 14066, E.O. 14068, and E.O. 14071 (see FAQs 1013, 1014, and 1015).
On November 21, 2024, OFAC also issued amended GL 55C to authorize all transactions prohibited by E.O. 14024 involving Gazprombank, or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, that are related to the Sakhalin-2 project (including such transactions involving Sakhalin Energy LLC) until June 28, 2025. GL 55C does not authorize transactions prohibited by the Russia-related CAPTA Directive, 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" ("Russia-related Sovereign Transactions Directive"), or transactions otherwise prohibited by the Russia Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).
On January 10, 2025, OFAC also issued amended GL 115A to authorize transactions related to civil nuclear energy involving the Covered Entities as well as Gazprombank Joint Stock Company (see FAQ 1203).
Date Updated: January 10, 2025