OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 108
Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked Persons or Vessels
(a) Except as provided in paragraph (c) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to one of the following activities involving the blocked persons described in paragraph (b) are authorized through 12:01 a.m. eastern standard time, November 6, 2024, provided that any payment to a blocked person must be made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR):
(1) The safe docking and anchoring in port of any vessels in which any person listed in paragraph (b) of this general license has a property interest (the “blocked vessels”);
(2) The preservation of the health or safety of the crew of any of the blocked vessels; or
(3) Emergency repairs of any of the blocked vessels or environmental mitigation or protection activities relating to any of the blocked vessels.
(b) The authorization in paragraph (a) of this general license applies to the following blocked persons listed on the Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List and any entity in which any of the following persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest:
(1) Gotik Shipping Co; or
(2) Plio Energy Cargo Shipping OPC Private Limited.
(c) This general license does not authorize:
(1) The entry into any new commercial contracts involving the property or interests in property of any blocked persons, including the blocked entities described in paragraph (b) of this general license, except as authorized by paragraph (a);
(2) The offloading of any cargo onboard any of the blocked vessels, including the offloading of liquefied natural gas of Russian Federation origin, except for the offloading of cargo that is ordinarily incident and necessary to address vessel emergencies authorized pursuant to paragraph (a) of this general license;
(3) Any transactions related to the sale of liquefied natural gas of Russian Federation
origin;
(4) Any transactions prohibited by Directive 2 under E.O. 14024, Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions;
(5) Any transactions prohibited by Directive 4 under E.O. 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation; or
(6) Any transactions otherwise prohibited by the RuHSR, including transactions involving the property or interests in property of any person blocked pursuant to the RuHSR, other than transactions involving the blocked persons described in paragraph (b) of this general license, unless separately authorized.
Lisa M. Palluconi
Acting Director
Office of Foreign Assets Control
Dated: September 5, 2024
1) Compare GTSR General License 21 and Iran General License O, which are two other GLs aimed at authorizing, on a time-limited basis, certain transactions related to blocked vessels and their designated owners. Compare also Russia-related General License 96 (same type of GL issued prior to this one). This GL is substantively identical to Russia-related General License 96, except two carveouts relate to “liquefied natural gas” instead of “crude oil or petroleum products,” presumably due to information concerning what is on board the blocked vessels. Compare also Russia-related General License 107 (virtually identical).