Russia-related GL 8C; amended FAQs

OFAC has posted a Notice of Recent Actions announcing it has issued Russia-related General License 8C, "Authorizing Transactions Related to Energy." Effective June 14, 2022, this license replaces and supersedes General License No. 8B in its entirety.

OFAC also published the following amended Frequently Asked Questions relating to the Russian Harmful Foreign Activities Sanctions:

• 967. What does Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive) prohibit?
• 976. Can a U.S. financial institution process transactions related to energy where a Russian financial institution sanctioned pursuant to Executive Order (E.O.) 14024 is involved?
• 977. What are transactions “related to energy” for purposes of Russia-related General License (GL) 8C?
• 978. For transactions authorized under Russia-related General Licenses (GL) 6A, 7A, or 8C what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?
• 1010. 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?
• 1011. My U.S. bank refused to process a requested payment related to energy despite the authorization in Russia-related General License (GL) 8C under Executive Order (E.O.) 14024. What can I do?
• 1012. Do I have to wind down energy-related transactions by the expiration date of Russia-related General License (GL) 8C?
• 1017. Does Russia-related General License (GL) 8C remain valid following the issuance of Executive Order (E.O.) 14066, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”?