On October 25, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published General Licenses (“GL”) 8H related to the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587 (the “RuHSR”).
GL 8H, which replaces GL 8G, extends to May 1, 2024, U.S. persons’ authority to conduct transactions with the following listed financial institutions for energy related transactions (e.g., the extraction, transport or purchase of petroleum):
Except for the Central Bank of the Russian Federation, all of the above financial institutions are “specially designated nationals” or “SDNs” and, unless another OFAC license exists, other transactions by U.S. persons with those entities are prohibited. Without the extension, the General License would have expired on November 1, 2024.
For additional information involving Russia-related sanctions, visit Locke Lord’s Russia Sanctions Resource Center.
This paper is intended as a guide only and is not a substitute for specific legal or tax advice. Please reach out to the authors for any specific questions. We expect to continue to monitor the topics addressed in this paper and provide future client updates when useful.
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