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ARTICLE · 20 FEBRUARY 2023

OFAC Issues Updates To Russian Harmful Foreign Activities Sanctions Regulations

Lewis Brisbois Bisgaard & Smith LLP
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In recent weeks, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued updates to several Russia-related general licenses and FAQs pertaining to the ...

United StatesInternational Law
Rebecca Stoddard
Rebecca Stoddard
Jane Luxton
Jane Luxton
Andrew Pidgirsky
Andrew Pidgirsky
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Washington, D.C. – (February 15, 2023) In recent weeks, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued updates to several Russia-related general licenses and FAQs pertaining to the Russian Harmful Foreign Activities Sanctions Regulations at 31 C.F.R. part 587. It is important that companies stay informed of the latest developments in Russia-related regulations as these updates, detailed below, could have significant impacts on their businesses.

General Licenses

General License 6

These updates expand the scope of General License (GL) 6, which authorizes certain transactions related to agriculture and healthcare services that have otherwise been banned by the Russian Harmful Foreign Activities Sanctions Regulations. This update, codified as GL 6C, supersedes and replaces GL 6B, which was issued in July 2022. Previously, GL 6 authorized only transactions related to the "production, manufacturing, sale, or transport"

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