General Licenses Applicable to the Russia Sanctions

Concurrent with the February 24 actions, OFAC also issued eight general licenses authorizing the following:

  • General License 5: official business of certain international organizations and entities, such as the International Centre for Settlement of Investment Disputes (ICSID) the International Federation of Red Cross and Red Crescent Societies.
  • General License 6: transactions (other than those prohibited by Directive 2) related to exportation or reexportation of agricultural commodities, medicine, and medical devices and transactions for the prevention, diagnosis, or treatment of COVID-19.
  • General License 7: transactions (other than those prohibited by Directive 2) related to overflights of, or emergency landings in, the Russian Federation by US registered, owned, or controlled aircraft and related to the provision of air ambulance services to individuals in the Russian Federation.
  • General License 8: transactions (other than those prohibited by Directive 2) until June 24, 2022, “related to energy” and that involve Vnesheconombank, Otkritie, Sovcombank, VTB Bank, or Sberbank. This authorization also applies to any entity in which one or more of these banks have a 50 percent or greater interest. The term “related to energy” has a defined meaning in the GL and covers a broad range of activity.
  • General License 9: transactions (other than those prohibited by Directive 2) until May 25, 2022, that are incident and necessary to certain dealings in debt or equity of Vnesheconombank, Otkritie, Sovcombank, VTB Bank, or Sberbank issued prior to February 24, 2022. This authorization also applies to any entity in which one or more of these banks have a 50 percent or greater interest.
  • General License 10: certain transactions (other than those prohibited by Directive 2) until May 25, 2022, necessary to wind down derivative contracts entered prior to 4:00PM EST, February 24, 2022, that include or are linked to Vnesheconombank, Otkritie, Sovcombank, VTB Bank, or Sberbank. This authorization also applies to any entity in which one or more of these banks have a 50 percent or greater interest.
  • General License 11: wind down transactions until March 26, 2022, involving Otkritie, Sovcombank, VTB Bank or any entity in which one or more of these banks have a 50 percent or greater interest.
  • General License 12: rejection of any transactions until March 26, 2022, involving Otkritie, Sovcombank, VTB Bankor any entity in which one or more of these banks have a 50 percent or greater interest.