OFAC Amends General License on Energy-related Russia Sanctions

OFAC amended a general license authorizing transactions under the "Russian Harmful Foreign Activities Sanctions Regulations," 31 CFR Part 587. General License No. 8C supersedes General License No. 8B in its entirety and authorizes all transactions "related to energy" otherwise prohibited under EO 14024 ("Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation") involving certain listed entities.

General License No. 8C also defines "related to energy" as "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."

The amended FAQs clarified (i) which type of transactions are authorized under General License 8C, (ii) prohibited transactions and (iii) relevant definitions.