The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 29 Sep 2025 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Russia-related General License ("GL") GL13O , which extends the authorization of certain administrative transactions prohibited by Directive 4 under E.O. 14024, until 12:01 a.m. Eastern Standard Time on January 9, 2026. Additionally, OFAC updated two Russia-related FAQs (999 and 1118) in connection with GL 13O, both making non-substantive changes.
- 26 Sep 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/7328184 ("GL INT/2025/7328184" or "GL") in respect of "Permitted Payments" (as defined by the GL) by His Majesty's Revenue and Customs (the "Revenue Authority) to "Frozen UK Bank Accounts" held by a UK designated person ("DP"). GL INT/2025/7328184 has been issued under all UK Autonomous Sanction Regulations listed in Annex I of the GL, which includes the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations").
- 26 Sep 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/2104808 ("GL INT/2022/2104808" or "GL"), which allows for the payment of "Service Fees" to banks (as defined by the GL) from accounts held by UK designated persons ("UK DPs"), pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations").
- 26 Sep 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2023/3179120 ("GL INT/2023/3179120" or "GL"), which allows for payments to "Water Companies" for water and sewage services by a designated person ("DP"), or on behalf of a DP, pursuant to the UK Autonomous Sanctions Regulations listed in Annex I of the GL, which includes the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations").
- 26 Sep 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/2300292 ("GL INT/2022/2300292" or "GL"), which allows for payments to "Energy Companies" (as defined by the GL) for gas and electricity by UK designated persons ("DPs"), or for or on behalf of a DP, who own or rent properties in the UK. The GL applies to the UK Autonomous Sanctions Regulations listed in Annex I of the GL, which includes the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations").
- 26 Sep 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") added three new FAQs (165 to 167) to the UK Financial Sanctions FAQs, which relate to general licenses applicable to the Russia (Sanctions) (EU Exit) Regulations 2019 (the "Russia Regulations"). The new FAQs seek to provide further clarification regarding:
- Payments by UK designated persons ("UK DPs") from non-frozen bank accounts to water and utility companies under General Licences INT/2023/3179120 and INT/2022/2300292;
- Whether banks can receive payments for service fees from a UK DP's non-frozen bank account under General Licence INT/2022/2104808; and
- Whether banks can charge service fees for payments that relate to regulatory exceptions.
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