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1198. In light of the designation of Shreya Life Sciences Private Limited (Shreya), are U.S. persons authorized to engage in transactions related to pharmaceutical and other humanitarian-related goods involving Shreya and its subsidiaries?
Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions.
OFAC has issued Russia-related General License (GL) 6D, which authorizes, among other things, certain transactions related to the production, manufacturing, sale, transport, or provision of medicine and medical devices. U.S. persons may continue to engage in authorized transactions involving Shreya under GL 6D. Additionally, non-U.S. persons generally would not face sanctions risk for engaging in transactions authorized for U.S. persons under general licenses issued pursuant to the Russian Harmful Foreign Activities Sanctions program. For further information, please review the OFAC Food Security Fact Sheet: Russia Sanctions and Agricultural Trade.
Date Released
October 30, 2024
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1) This GL was issued concurrently with OFAC's designation of Shreya Life Sciences Private Limited pursuant to EO 14024.
According to OFAC:
Since 2023, India-based Shreya Life Sciences Private Limited (Shreya) has sent hundreds of shipments of U.S.-trademarked technology, including advanced servers designed for artificial intelligence and machine learning, to Russia. These shipments, totaling tens of millions of dollars, have included high-priority technology that Russia seeks to procure for its weapons programs. Shreya has sent technology to U.S.-designated Russian technology companies Silkway Limited Liability Company and OOO Lanprint, as well as Mein Chein, a Russia-based wholesaler and importer of computer equipment founded in 2023 that offers “turnkey import” services. Shreya and Mein Chein are being designated pursuant to E.O. 14024 for operating or having operated in the technology sector of the Russian Federation economy...