Morgan Lewis US and Russia Sanctions Update
US Direct Sanctions - SDNS (cont'd)
Two Special Cases - Glavgosekspertiza and FSB Designations / Related GLS
Two general licenses issued by OFAC to respond to / correct overbroad reach of the
Sept. 2016 and Dec. 2016 designations of GGE and FSB as SDNS (re GGE activities
in Crimea and FSB alleged involvement in hacking / election-tampering):
OFAC General License No. 11 of 20 Dec. 2016 (entitled "Authorizing Certain Transactions
with FAU Glavgosekspertiza Rossii" - GGE)
gives general authorization for "all transactions and activities ... that are ordinarily incident and
necessary to requesting, contracting for, paying for, receiving, or utilizing a project design review
or permit from [GGE]'s office(s) in [Russia]"
except for carving out (i.e., still prohibiting) anything to do with GGE relating to Crimea
OFAC General License No. 1B of March 2021 (as replacing/slightly amending earlier GL
1A) under the cyber- and now also WMD-related sanctions - entitled "Authorizing Certain
Transactions with the Federal Security Service" (FSB)
gives authorization for "all transactions and activities ... necessary and ordinarily incident to ...
[r]equesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or
notifications issued or registered by [FSB] for the importation, distribution, or use of information
technology products" in Russia
but export, reexport, or provision of any goods or technology subject to the EAR requires BIS
license, and fees payable to FSB must not be ≥$5,000 annually
compliance with FSB law enforcement/ administrative actions or investigations as well as
regulations administered by FSB is also authorized
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