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978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, 8L, or GL 115A what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?
On January 10, 2025, OFAC issued amended General License (GL) 8L to authorize the wind-down of transactions related to energy involving certain Russian financial institutions sanctioned pursuant to E.O. 14024 through 12:01 a.m. eastern daylight time, March 12, 2025. GLs 6D, 7A, 8L, or 115A do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive). Consequently, in order for a U.S. financial institution to engage in transactions authorized...
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1) Compare Archived Cuba FAQs - # 6, and the related graphic. This is effectively a "U-turn" GL.
2) The FAQ clarifies what is not clear from the GLs referenced, i.e. that the involvement of blocked banks is authorized when the blocked banks are involved in the processing of underlying transactions described by the GLs.
3) Query: can the blocked banks referenced be involved in transactions where the underlying transaction is exempt, e.g., an exempt informational materials or travel transaction? It would appear so.
4) Query: why do GLs 6, 7 and 8 contain a "correspondent account or payable-through account" exclusion, while GL 5 (Official Business of Certain International Organizations and Entities) does not? Can the United Nations Federal Credit Union maintain a correspondent account for...