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1,017. Does Russia-related General License (GL) 8A remain valid following the issuance of Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine”?
Yes. GL 8A, which authorizes certain transactions “related to energy” involving specified Russian financial institutions, remains in effect until 12:01 eastern daylight time, June 24, 2022, unless renewed. However, GL 8A does not authorize any transactions prohibited by E.O. of March 8, 2022 (see FAQs 976-978 and 1,010-1,012).
Date Released
March 8, 2022
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1) Refer generally to comments to EO 14066.
The FAQ says " GL 8A does not authorize any transactions prohibited by E.O. of March 8, 2022". Can a blocked Russian bank be used to process a transaction that is otherwise prohibited by EO 14066 but authorized by Russia-related General License 16 (e.g. letter of credit transaction involving a blocked bank related to the importation of oil into the U.S.). It seems that the answer is yes. The FAQ appears aimed at specifying that transactions otherwise described by GL 8A are not authorized by GL 8A if they are also within the scope of the prohibition of EO 14066, unless the transactions are separately authorized by EO 14066.
* FAQ amended on 6-14-22 to reference