PRINT
1039. Are transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities to, from, or transiting the Russian Federation that involve Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO authorized under OFAC sanctions?
Yes. On May 8, 2022, OFAC designated Agropromyshlennyi Kompleks Voronezhskii OOO, Anninskii Elevator OOO, and Azovskaya Zernovaya Kompaniya OOO pursuant to Executive Order (E.O.) 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Joint Stock Company Moscow Industrial Bank (MIB), which was also designated on May 8, 2022 pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. Russia-related General License (GL) 6B authorizes, among other activities, certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), that...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) Read in conjunction with Russia-related General License 6. This GL may be aimed at confirming, to the extent there was otherwise confusion, that Russia-related General License 6 applies transactions related to warehousing and storage (in the case of ANNINSKI ELEVATOR, OOO [1]). It is also possible that the FAQ is aimed at confirming that the purpose of the GL is not only to authorize the processing of otherwise prohibited payments by banks blocked pursuant to EO 14024. In this case, it is clear that that GL would authorize actual payments to SDNs (compare comments to FAQ # 990).
[1] See https://www.dnb.com/business-directory/company-profiles.anninski_elevator_ooo.68dfc5e9391ae3b95c04cf7bb21e5d02.html
2) FAQ amended on 7-15-22 to add the reference to FACT SHEET: Russia Sanctions and Agricultural Trade.