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

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

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

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