OFAC Issues Clarifying Guidance On Its Russia Sanctions And Amends Several General Licenses

On March 2, 2022, the Department of the Treasury's Office of Foreign Assets Control (OFAC) provided clarifying guidance on the implementation of several of its sanctions involving Russia.  In doing so, OFAC noted that since implementation of the sanctions, "Russia has taken steps to use exporters to act as their agents and help them raise resources to prop up their currency and fund their priorities. [This additional] guidance makes clear that such actions on behalf of Russia's Central Bank are prohibited, closing off attempts to access the U.S. financial system."  The clarifications and guidance focus on interpretation of transactions authorized by Directive 4 under Executive Order (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, involving the Central Bank of the Russian Federation, the National Wealth