United States releases new Russia-related FAQs

The Office of Foreign Assets Control (OFAC) released three new Russia-related “frequently asked questions” (FAQs).

The Office of Foreign Assets Control (OFAC) released three new Russia-related “frequently

The Department of the Treasury's Office of Foreign Assets Control (OFAC) released three new Russia-related “frequently asked questions” (FAQs).

Read the OFAC release

Full text of new FAQs (hyperlinks deactivated)

Russian Harmful Foreign Activities Sanctions

1,012. Do I have to wind down energy-related transactions by the expiration date of Russia-related General License (GL) 8A?

GL 8A authorizes energy-related transactions through 12:01 a.m. eastern daylight time, June 24, 2022, unless renewed.  In the event that GL 8A is not renewed, OFAC intends to issue a general license authorizing the orderly wind down of activities covered by GL 8A.

Released on 03/04/2022

Russian Harmful Foreign Activities Sanctions

1,011. My U.S. bank refused to process a requested payment related to energy despite the authorization in Russia-related General License (GL) 8A under Executive Order (E.O.) 14024.  What can I do?

The Office of Foreign Assets Control (OFAC) encourages persons to connect with their financial institution regarding the status of any payment.  In addition, persons with questions about engaging in or processing transactions related to GL 8A can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490. 

Released on 03/04/2022

Russian Harmful Foreign Activities Sanctions

1,010. My company transports Russian oil for sale to the United States and third countries.  Can I continue to transport or sell Russian-origin oil without violating sanctions pursuant to Executive Order (E.O.) 14024?

Yes.  In general, energy-related activities — including the purchase, sale, or transport of Russian-origin oil, gas, or other energy-related products by U.S. or non-U.S. persons — remain permissible under E.O. 14024.  The energy sector of the Russian Federation economy itself is not subject to comprehensive sanctions.  However, targeted prohibitions or restrictions may apply to certain energy-related dealings with specified Russian persons under other sanctions authorities, such as prohibitions on certain dealings with Russian entities subject to directives issued under E.O. 13662.

The Office of Foreign Assets Control (OFAC) has imposed expansive sanctions on persons that operate or have operated in the financial services sector of the Russian Federation economy (see FAQ 966).  To limit the degree to which these financial services sector sanctions may inhibit energy-related transactions, OFAC issued Russia-related General License (GL) 8A authorizing U.S. persons to process energy-related transactions involving the sanctioned Russian financial institutions identified in GL 8A.  GL 8A expires at 12:01 a.m. eastern daylight time, June 24, 2022, unless renewed (see FAQs 976, 977, 978, and 999).

Energy-related transactions authorized in GL 8A include payments connected with a variety of upstream and downstream activity, including the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of energy for import from or export to Russia, as well as financing, loading, or unloading related to such processes (see FAQ 977).

Released on 03/04/2022

For more information, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094
E: labad@kpmg.com

Irina Vaysfeld
T: 212-872-2973
E: ivaysfeld@kpmg.com

Amie Ahanchian
T: 202-533-3247
E: aahanchian@kpmg.com

Christopher Young
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E: christopheryoung@kpmg.com

Gisele Belotto
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E: gbelotto@kpmg.com

George Zaharatos
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E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
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E: adoornaert@kpmg.com

Jessica Libby
T: 612-305-5533
E: jlibby@kpmg.com

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