GL 115A generally authorizes certain transactions related to civil nuclear energy involving certain entities that are sanctioned pursuant to Executive Order 14024. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects and operations initiated or under construction as of November 21, 2024: the extraction, production, refinement, conversion, enrichment, fabrication, transport, or purchase of uranium in any form; the production, generation, transmission, or exchange of nuclear power, fuel, or waste; and the operation of civil nuclear energy projects. However, GL 115A does not authorize, for instance, transactions involving certain sanctioned Russian financial institutions related to the development of new civil nuclear energy power plants after November 21, 2024, or related to the Paks II nuclear power plant project, including Paks II. Nuclear Power Plant Private Limited Company (Paks II. Ltd.), or any successor project.

Non-U.S. persons generally do not risk exposure to U.S. sanctions for engaging in transactions with blocked persons, including transactions related to existing civil nuclear energy as described in GL 115A, where those transactions would not require a specific license if engaged in by a U.S. person.

Updated: January 10, 2025

The Office of Foreign Assets Control (OFAC) has issued several authorizations related to U.S. and third-country diplomatic or consular missions operating in or outside of 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.

Third-Country Diplomatic or Consular Mission Outside of Russia: Russia-related General License (GL) 119 authorizes, subject to certain conditions, all transactions ordinarily incident and necessary to the official business of diplomatic or consular missions located outside of the Russian Federation that are prohibited by E.O. 14024 and involve Gazprom Neft, or any entity in which Gazprom Neft owns, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. eastern standard time, February 27, 2025.

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.

Date Updated: January 10, 2025

On June 12, 2024, OFAC issued Russia-related general licenses (GLs) GL 99, GL 100, and amended GL 8J, authorizing certain transactions involving MOEX, NCC, NSD, or any entity in which one of these entities owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, "the Blocked Entities").

GL 99 authorizes the wind down of transactions involving the Blocked Entities, as well as certain transactions related to the divestment to non-U.S. persons of debt or equity issued or guaranteed by, or derivative contracts involving, the Blocked Entities. For example, GL 99 would authorize a U.S. person to divest their equity in MOEX to a non-blocked non-U.S. person. This authorization expired at 12:01 a.m. eastern daylight time August 13, 2024. See GL 99 for more information.

GL 100 authorizes certain transactions for the divestment to non-blocked, non-U.S. persons of debt or equity, or for the conversion of currencies, involving one or more of the Blocked Entities solely as a securities, trade, or settlement depository, central counterparty or clearing house, or public trading market. GL 100 is intended to cover the divestment of debt or equity of non-blocked companies that may be traded on or through one of the Blocked Entities in their capacity as a securities, trade, or settlement depository, central counterparty or clearing house, or public trading market. For example, GL 100 would authorize a U.S. person to divest their equity in a non-blocked Russian company that is being traded on MOEX to a non-blocked, non-U.S. person. This example would be distinct from the divestment of equity in MOEX itself, which would be covered by GL 99. GL 100 would also authorize U.S. persons to transact with one of the Blocked Entities to the extent ordinarily incident and necessary to convert U.S. dollars to another currency, or vice versa. This authorization expired at 12:01 a.m. eastern daylight time August 13, 2024. See GL 100 for more information.

GL 8L authorizes certain transactions related to energy involving NCC. See FAQ 976 for more information. On January 10, 2025, OFAC issued amended 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. OFAC also issued GL 115A to authorize transactions related to civil nuclear energy involving certain sanctioned Russian financial institutions, including those listed in GL 8L.

Updated: January 10, 2025

Treasury remains focused on counteracting activity that involves sanctions evasion or third-country support to Russia's military-industrial base. At the same time, legitimate humanitarian activity and agricultural and medical trade are not the target of our sanctions. Accordingly, FFIs may continue to conduct or facilitate any transaction(s) or provide any service related to activities that are otherwise authorized or exempted under the Russian Harmful Foreign Activities Sanctions program. Foreign persons do not risk the imposition of sanctions for engaging in transactions authorized for U.S. persons under General Licenses issued under the Russian Harmful Foreign Activities Sanctions program.

FFIs may continue to rely on Treasury's existing authorizations in place for transactions related to agricultural commodities, medicine, medical devices and related replacement parts, components, or software updates, the Coronavirus Disease 2019 (General License (GL) 6D), certain civil nuclear energy-related transactions (GL 115A), certain transactions in support of non-governmental organizations (GL 27), official business of third-country diplomatic or consular missions located in the Russian Federation (GL 20), certain transactions and official business of certain international organizations and entities by employees, grantees, or contractors thereof (31 CFR 587.510). Additionally, the importation or exportation of information or informational materials and transactions ordinarily incident to travel to or from any country are exempt under the International Emergency Economic Powers Act (IEEPA).

See OFAC's Advisory to Foreign Banks on Russia Sanctions Risks for additional guidance.

Date Updated: January 10, 2025

Section 1(a)(i) of E.O. 14024 imposes sanctions with respect to any person determined by the Secretary of the Treasury, in consultation with the Secretary of State, to operate or have operated in the technology sector or the defense and related materiel sector of the Russian Federation economy, or any other sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State. As of January 10, 2025, persons may be sanctioned pursuant to E.O. 14024 for operating or having operated in the following sectors of the Russian Federation economy:

OFAC expects to promulgate regulations that define the terms (i) architecture sector of the Russian Federation economy, (ii) engineering sector of the Russian Federation economy, (iii) construction sector of the Russian Federation economy, (iv) manufacturing sector of the Russian Federation economy, (v) transportation sector of the Russian Federation economy; (vi) technology sector of the Russian Federation economy; (vii) defense and related materiel sector of the Russian Federation economy; (viii) aerospace sector of the Russian Federation economy; (ix) financial services sector of the Russian Federation economy; (x) electronics sector of the Russian Federation economy; (xi) marine sector of the Russian Federation economy, and (xii) energy sector of the Russian Federation economy consistent with the following:

Architecture sector of the Russian Federation economy: The term architecture sector of the Russian Federation economy includes activities such as advising; pre-designing; designing; preparing sketches, reports, studies, assessments, site plans, working drawings, specifications, cost estimates, as-built drawings, or other materials; contract administration; site selection; and inspections concerning architectural and related matters involving the Russian Federation.  Such activities may be related to the following types of projects, e.g.: residential, institutional, leisure, commercial, and industrial buildings and structures; recreational areas; transportation infrastructure; land subdivisions; urban planning; landscape architecture; and not necessarily relate to a new construction project. The term additionally includes any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the architecture sector of the Russian Federation economy.

Engineering sector of the Russian Federation economy: The term engineering sector of the Russian Federation economy includes activities such as advising; designing; recommending; consulting; constructing; installing, surveying; preparing studies, specifications, cost estimates, working drawings, process flow diagrams, arrangement drawings, or other materials; map making; planning; testing; analysis; and inspecting for engineering and related matters involving the Russian Federation.  Such activities may be undertaken during any phase of an engineering project of any type and may not necessarily relate to a new construction or development project.  The term additionally includes any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the engineering sector of the Russian Federation economy.

Construction sector of the Russian Federation economy: The term construction sector of the Russian Federation economy includes activities such as the production, procurement, devising, framing, design, testing, financing, distribution, or transport involving the Russian Federation, of goods, services, or technology to fabricate, shape, alter, maintain, or form any buildings or structures, including the on-site development, assembly, or construction of residential, commercial, or institutional buildings, or of transportation infrastructure, in the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the construction sector of the Russian Federation economy.

Manufacturing sector of the Russian Federation economy: The term manufacturing sector of the Russian Federation economy includes activities such as the creation, modification, repair, testing, or financing, of goods by manual labor or machinery involving the Russian Federation and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the manufacturing sector of the Russian Federation economy.  Note that persons conducting or facilitating transactions that are exempt or authorized by OFAC—such as those related to the provision of agricultural commodities, food, medicine, or medical devices, or related to civil nuclear energy—will not be subject to sanctions under E.O. 14024.

Transportation sector of the Russian Federation economy: The term transportation sector of the Russian Federation economy includes activities such as the production, manufacturing, testing, financing, distribution or transport to, from, or involving the Russian Federation of any mode of transport or any goods, services, or technology for the movement or conveyance of persons or property and the loading, unloading, or storage incidental to the movement of such persons or property; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the transportation sector of the Russian Federation economy.

Technology sector of the Russian Federation economy: The term technology sector of the Russian Federation economy includes activities such as the production, procurement, research, development, design, engineering, testing, servicing, financing, distribution, use, or transport involving the Russian Federation, of software, equipment, electronics, items, tools, materials, or devices, and any components, parts, or accessories of the foregoing, related to the fields of computing, engineering, applied mathematics, or applied sciences involving the Russian Federation and any related activities, including the provision or receipt of goods or services involving the technology sector of the Russian Federation economy.

Defense and related materiel sector of the Russian Federation economy: The term defense and related materiel sector of the Russian Federation economy includes military, armed forces, or security forces of or within the Russian Federation; the use of arms or related materiel by military, armed forces, or security forces of or within the Russian Federation; any person designing, developing, manufacturing, supplying, financing, procuring, or distributing goods, services, or technology to, from, or involving military, armed forces, or security forces of or within the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology involving the defense and related materiel sector of the Russian Federation economy.  The term defense and related materiel sector of the Russian Federation economy also includes acquisition, possession, procurement, research, design, development, testing, evaluation, manufacture, maintenance, upgrade or refurbishment, shipping, supply, sale, transfer, or storage to, from, within, for, transiting, or on behalf of the Russian Federation of arms or related materiel of all types; enablers, aggregates, components, parts, as well as related documentation and instructions for any such arms or related materiel; or training for the use of included systems, provision of simulation equipment, documentation (including training manuals, maintenance orders, or technical bulletins), prototypes, software upgrades, and licensing and manufacturing agreements for such items.

Aerospace sector of the Russian Federation economy: The term aerospace sector of the Russian Federation economy includes activities such as the production, procurement, development, design, testing, servicing, financing, distribution, use, or transport involving the Russian Federation and its airspace, of aircraft or any other device used or intended to be used for flight or activities in the air or in space, missiles, unmanned aerial vehicles, space-based vehicles, satellites, high-altitude balloons, any other device that operates above the surface of the earth, and any items, components, parts, or accessories intended for the foregoing; airports or any other area of land or water used or intended to be used for a purpose related to the aerospace sector of the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology involving the aerospace sector of the Russian Federation economy.

Financial services sector of the Russian Federation economy: The term financial services sector of the Russian Federation economy includes economic or financial services in, involving the Russian Federation, including government-operated and private banks, depository institutions, credit card companies, investment banking services, foreign exchange services, money services businesses, payday lenders, mortgage companies, securities exchanges, securities dealers, asset managers, insurance companies, other financial institutions, and any persons in the business of accepting deposits, transferring funds, facilitating investment, making, granting, transferring, holding, or brokering loans or credits, or purchasing or selling foreign exchange, securities, commodity futures or options, or procuring purchasers and sellers thereof, as principal or agent; and any related activities, including the provision or receipt of goods, services, or technology involving the financial services sector of the Russian Federation economy.

Electronics sector of the Russian Federation economy:  The term electronics sector of the Russian Federation economy includes activities such as the production, procurement, development, design, testing, servicing, financing, distribution, use, or transport to, from, or involving the Russian Federation, of computers, computer peripherals, semiconductors, electronic capacitors or resistors, coils, circuit boards, cryptographic software and hardware, or devices that control, direct, or utilize an electric current, and any items, components, parts, or accessories of the foregoing; and any related activities, in, or involving the Russian Federation, including the provision or receipt of goods, services, or technology involving the electronics sector of the Russian Federation economy.

Marine Sector of the Russian Federation economy: The term marine sector of the Russian Federation economy includes activities such as the production, procurement, development, design, testing, servicing, financing, distribution, use, or transport, to, from, or involving the Russian Federation or its marine waterways or oceanic exclusive economic zone, of vessels, or any device used or intended to be used in or otherwise relating to the sea or any navigable body of water, and any items, components, parts, or accessories of the foregoing; any activity relating to the sea or any body of navigable water; ports or any area of land or water used or intended to be used for any purpose related to the marine sector of the Russian Federation, including shipping; and any related activities, including the provision or receipt of goods, services, or technology involving the marine sector of the Russian Federation economy. The term includes the financing, sale, supply, or transfer of vessels to or from, directly or indirectly, the Russian Federation or any Russian Federation person.

Energy sector of the Russian Federation economy: The term energy sector of the Russian Federation economy includes activities such as the procurement, exploration, extraction, drilling, mining, harvesting, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, manufacturing, testing, financing, distribution, purchase or transport to, from, or involving the Russian Federation, of petroleum, including crude oil, lease condensates, unfinished oils, natural gas, liquefied natural gas, natural gas liquids, or petroleum products, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels; the development, production, testing, generation, transmission, financing, or exchange of power, through any means, including nuclear, electrical, thermal, and renewable, to, from,  or involving the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the energy sector of the Russian Federation economy.

Date Updated: January 10, 2025

The determination made on February 24, 2023 pursuant to Executive Order (E.O.) 14024 authorizes sanctions on any person determined to operate or have operated in the metals and mining sector of the Russian Federation economy. Non-U.S. persons may also be exposed to sanctions for activities with persons blocked pursuant to E.O. 14024 (see FAQ 980), including persons blocked following a determination that such persons operate or have operated in the metals and mining sector.

However, OFAC does not intend to target persons for operating in the metals and mining sector where the provision of goods or services is solely for the safety and care of personnel, protection of human life, prevention of accidents or injuries, maintenance or repair necessary to avoid environmental or other significant damage, or activities related to environmental mitigation or remediation. Examples of such goods include personal protective equipment, safety devices, ventilation systems, and alarm systems; examples of such services include rescue and accident response services, cleaning, safety inspections, and services necessary for use of the goods described above.

In addition, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, including in the metals and mining sector, where those transactions would not require a specific license if engaged in by a U.S. person. For example, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions for engaging in transactions in the metals and mining sector if such transactions would be authorized for U.S. persons by General License (GL) 115A (authorizing certain civil nuclear energy-related transactions) or by GL 6D (authorizing certain transactions related to the production, manufacturing, sale, transport, or provision of medicine or medical devices, including certain industrial isotopes used in nuclear medicine, among other things).

Date Updated: January 10, 2025

Yes. GL 8L, which authorizes the wind-down of energy related transactions  involving specified Russian financial institutions, remains in effect until 12:01 a.m. eastern daylight time, March 12, 2025, unless renewed.  However, GL 8L does not authorize any transactions prohibited by E.O. 14066 (see FAQs 976-978 and 1010-1012).

Updated: January 10, 2025

On January 10, 2025, the Office of Foreign Assets Control (OFAC) amended GL 8L to authorize the wind-down of energy-related transactions through 12:01 a.m. eastern daylight time, March 12, 2025. OFAC issued GL 115A to authorize transactions related to civil nuclear energy involving certain sanctioned Russian financial institutions, including those listed in GL 8L.

Updated: January 10, 2025

The Office of Foreign Assets Control (OFAC) encourages persons to connect with their financial institution regarding the status of any payment.  In addition, persons with questions about engaging in or processing transactions related to GL 115A can contact the OFAC Compliance Hotline.

Updated: January 10, 2025

OFAC issued Russia-related General Licenses (GLs) 8L and 115A to authorize the wind-down of certain energy-related transactions and civil nuclear energy-related transactions, including those involving the Central Bank of the Russian Federation, that would be prohibited by the Russia-related Sovereign Transactions Directive (see FAQs 976 and 977).

OFAC issued GL 13L to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons' day-to-day operations in the Russian Federation. For further information on the types of transactions authorized by GL 13L, see FAQ 1118.

OFAC also issued GL 14, authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity's sole function in the transaction is to act as an operator of a clearing and settlement system. GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction. In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity. See FAQ 1003.

Note that GL 8L, GL 13L, GL 14, and GL 115A continue to authorize against the Russia-related Sovereign Transactions Directive.

Date Updated: January 10, 2025

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. GLs 6D, 7A, 8L, or 115A do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities 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” (Russia-related CAPTA Directive). Consequently, in order for a U.S. financial institution to engage in transactions authorized under these GLs (e.g., a funds transfer related to energy), all such funds transfers must be processed indirectly through a non-sanctioned, non-U.S. financial institution. 

Examples of authorized and prohibited funds transfers under GLs 6D, 7A, 8L, and 115A include:

Payment from third-country originator

Authorized payment from third-country originator to beneficiary with an account at a sanctioned institution:

Prohibited payment from third-country originator to beneficiary with an account at a sanctioned institution: 

 

Payment from U.S. originator

Authorized payment from U.S. originator to beneficiary with an account at a sanctioned institution:

Prohibited payment from U.S. originator to beneficiary with an account at a sanctioned institution: 

In each of the above examples, the underlying funds transfer must be authorized under the applicable GL.

Updated: January 10, 2025

On January 10, 2025, OFAC issued amended 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. For the purposes of GL 8L, the term "related to energy" means the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources. This definition remains unchanged from GL 8.

Updated: January 10, 2025

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

The Russia-related CAPTA Directive prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive. Please see the Russia-related CAPTA Directive for the definition of the terms "U.S. financial institution" and "foreign financial institution" for purposes of this directive. Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Annex 1 to the Russia-related CAPTA Directive lists the foreign financial institutions determined to be subject to the prohibitions as of March 26, 2022. Foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including the foreign financial institutions listed in Annex 1, can be found on the Office of Foreign Assets Control's (OFAC) List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List). Relevant entries on the CAPTA List will denote when a foreign financial institution became subject to the prohibitions of the Russia-related CAPTA Directive, as well as when the prohibitions of the Russia-related CAPTA Directive come into effect with respect to that foreign financial institution.

The below table identifies the dates the prohibitions of the Russia-related CAPTA Directive take effect for (i) foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive, and (ii) foreign financial institutions otherwise determined to be subject to its prohibitions and added to the CAPTA List.

U.S. financial institutions must close any correspondent or payable-through account maintained for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, by the relevant effective date. Separately, as of the relevant effective date, U.S. financial institutions may not process transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, and must reject such transactions unless exempt or authorized by OFAC.

Accordingly, after the relevant effective date, U.S. financial institutions must reject any transaction involving a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive or involving that foreign financial institution's property or interests in property. This includes rejecting transactions related to any securities (including depositary receipts) issued by a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including secondary market trading. For certain authorized securities-related transactions, see GL 9C and FAQ 981. By virtue of the prohibition on the processing of transactions for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, U.S. financial institutions are also prohibited from engaging in transactions with a covered foreign financial institution in connection with the foreign financial institution's role as a local custodian for depositary receipt issuances.

The Russia-related CAPTA Directive does not impose blocking sanctions and, thus, does not require U.S. financial institutions (or other U.S. persons) to block the assets of foreign financial institutions determined to be subject to the prohibitions of this directive. However, U.S. persons should be aware that foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662.

OFAC issued several Russia-related general licenses (GLs) authorizing certain transactions involving the foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive, including:

• GL 6D: authorizing transactions related to (1) the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or (3) ongoing clinical trials and other medical research activities;
• GL 7A: authorizing overflight payments, emergency landings, and air ambulance services;
• GL 8L: authorizing the wind-down of transactions related to energy through 12:01 a.m. eastern daylight time, March 12, 2025;
• GL 27: authorizing transactions in support of nongovernmental organizations' activities; and
• GL 115A: authorizing transactions related to civil nuclear energy.

On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.

For additional information, please see FAQs 976, 977, 978, 979, 981, 982 and 990.

Date Updated: January 10, 2025