Back

OFAC FAQ (Current) # 501 - Cyber-related Sanctions

Date issued: Apr. 27 2023

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

PRINT
501. What does General License 1C (GL 1C), “Authorizing Certain Transactions with the Federal Security Service,” authorize?

GL 1C authorizes transactions with the Federal Security Service (a.k.a. Federalnaya Sluzhba Bezopasnosti) (a.k.a. FSB) that are ordinarily incident and necessary to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the importation, distribution, or use of certain information technology products in the Russian Federation. It also authorizes transactions ordinarily incident and necessary to compliance with rules and regulations administered by, and certain actions or investigations involving, the Federal Security Service.

This general license does not authorize U.S. persons to engage in transactions with the Federal Security Service, except for the limited purposes described above, nor does it authorize the exportation, reexportation, sale or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any goods, services, or...

Click the appropriate link below for access to this file.

Click the appropriate link below for access to this file.

TURBOFAC Commentary (319 words)

Notes:

1) Typically, OFAC does not generally license a transaction type unless it considers the authorized transaction to be within the scope of a prohibition.

Here OFAC authorizes "Requesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or notifications issued or registered by the Federal Security Service." Characterizing "permits" as property in which the issuer has an interest is consistent with OFAC's past practice. "Requesting" the permits would also be prohibited but for the license as an "attempt" to deal in the property.

OFAC also generally licenses transactions incident to "[c]omplying with rules and regulations administered by the Federal Security Service." Even though OFAC ordinarily does not license that which would be permissible but for the license, here the usual caveat that the activities are licensed to the extent "otherwise prohibited" tends against a reading that OFAC considers...