GL 1 is a technical fix to earlier sanctions restrictions imposed by OFAC on the FSB in December 2016 in response to Russia’s alleged cyber-related interference in the 2016 U.S. elections. Please see our previous client alert here. OFAC issued GL 1 in response to complaints from U.S. companies that were unable to import many consumer technology products into Russia without a permit from the FSB, Russia’s principal security agency.
GL 1 does not authorize the exportation, reexportation or provision of goods, technology or services to the Crimea region of Ukraine. GL 1 also does not authorize the export, reexport, or provision of goods or technology to or on behalf of the FSB, except for the limited purposes described above and authorized under GL 1. Moreover, the FSB remains on BIS’s Entity List at this time. Accordingly, until such time as BIS removes the FSB from its Entity List, additional licensing requirements and restrictions apply to any contemplated exports, reexports and transfers of products subject to the EAR to the FSB. BIS has also implemented a presumption-of-denial policy to any license applications for exports, reexports or transfers to the FSB. We will continue to monitor developments as they unfold and will keep you informed.
*This blog post was originally on AG Trade Law.