U.S. issuance of Russia-related guidance items

General licenses, determinations pursuant to executive orders, and new and amended FAQs

General licenses, determinations pursuant to executive orders, and FAQs

The Department of the Treasury's Office of Foreign Assets Control (OFAC) today issued Russia-related guidance items—including general licenses, determinations pursuant to executive orders, and new and amended “frequently asked questions” (FAQs). 

  • General License 51  [PDF 103 KB]—Authorizing the wind down of transactions involving limited liability company group of companies Akvarius
  • General License 52 [PDF 155 KB]—Journalistic activities and establishment of news bureaus
  • Determination pursuant to section 1(a)(i) of Executive Order 14024 [PDF 140 KB]
  • Determination pursuant to section 1(a)(ii) of Executive Order 14071 [PDF 156 KB]—Prohibitions related to certain quantum computing services
  • FAQs 1080 - 1086
    • 1080. I am a U.S. person with an account at a Russian financial institution blocked pursuant to Executive Order (E.O.) 14024.  What am I required or allowed to do under OFAC sanctions with respect to such accounts? 
    • 1081. Am I required to show official documentation that I’ve closed my account at a Russian financial institution blocked pursuant to Executive Order (E.O.) 14024 in order to take advantage of Russia-related General License (GL) 50? 
    • 1082. National Payment Card System Joint Stock Company (NSPK) is not a blocked entity under the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).  Do non-U.S. financial institutions risk exposure to sanctions for contracting or otherwise dealing with NSPK? 
    • 1083. What actions were taken on September 15, 2022 related to certain quantum computing services?
    • 1084. For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Quantum Computing Services” (“the determination”),  what is meant by the term “quantum computing services”?
    • 1085. Does the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14024 with regard to the quantum computing sector of the Russian Federation economy mean that all persons that operate or have operated in these sectors of the Russian Federation economy are sanctioned by OFAC?
    • 1086. For the purposes of the determination of September 15, 2022 made pursuant to Executive Order (E.O.) 14024, what is meant by the term “quantum computing sector of the Russian Federation economy”?
  • Amended FAQs (1033, 1034, 1059, 1061, 1062)
    • 1033. What actions were taken on May 8, 2022 related to certain accounting, trust and corporate formation, and management consulting services?
    • 1034. For the purposes of the determination of May 8, 2022 made pursuant to Executive Order (E.O.) 14071, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” what is meant by the terms “accounting,” “trust and corporate formation,” and “management consulting” services?
    • 1059. Do the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” and on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services” (“the determinations”), prohibit U.S. persons from providing services to persons located outside of the Russian Federation that are owned or controlled by persons located in the Russian Federation?
    • 1061. Do the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” and on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services” (“the determinations”), prohibit U.S. persons from working as employees of entities located in the Russian Federation?
    • 1062. Do the prohibitions imposed by the determinations made pursuant to Executive Order (E.O.) 14071 on May 8, 2022, “Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services,” and on and on September 15, 2022, “Prohibitions Related to Certain Quantum Computing Services,” apply to services provided to a parent company located in the Russian Federation by a U.S. subsidiary?

In addition, OFAC's list of specially designated nationals (SDN list) was updated. Read the OFAC release

 

For more information on sanctions and other responses to Russia’s war on Ukraine, visit KPMG’s dedicated website.

Contact a professional with KPMG’s Trade & Customs services:

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Christopher Young
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Andy Doornaert
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Jessica Libby
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