OFAC Issues General Licenses on Russian Agricultural Trade

OFAC published four new general licenses, a food security fact sheet on "Russian Sanctions and Agricultural Trade" and three amended FAQs.

The new general licenses, issued under the "Russian Harmful Foreign Activities Sanctions Regulations" (31 CFR Part 587), include:

• General License 6B, which defines transactions related to agricultural commodities, medicine, and medical devices;

• General License 25C, which authorizes transactions related to certain telecommunications and internet-based communications;

• General License 30A, which permits transactions involving SEFE securing energy for Europe GmbH otherwise prohibited by Directive 3 under EO 14024 ("Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation"); and

• General License 44, which grants authority to export or reexport certain accounting services to U.S. individuals located within the Russian Federation.

OFAC also published a fact sheet intending to "further clarify agricultural commodities (including fertilizer), agricultural equipment, or medicine relating to Russia are not the target of U.S. sanctions." OFAC asserted that due to Russia's invasion of Ukraine, issues of food insecurity, climate change and COVID-19 increased. OFAC expressed optimism that it can address these concerns by expanding agricultural and medical authorization in Ukraine.

The amended FAQs provide clarification on transactions relating to (i) telecommunication and internet-based communication and (ii) the exportation and reexportation of agricultural commodities. Additionally, the FAQs extended guidance relating to the Russia-related CAPTA Directives.