OFAC issues licences for financial dealings with sanctioned parties

The US Treasury Department’s Office of Financial Assets Control (‘OFAC’) has issued two new general licences authorising certain transactions with otherwise-sanctioned entities.

GL38 provides: ‘[A]ll transactions ordinarily incident and necessary to the processing of pension payments to (1) U.S. persons or (2) non-U.S. persons not located in the Russian Federation, that are prohibited by Executive Order (E.O.) 14024 are authorized, provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to E.O. 14024.’

GL50 provides: ‘[A]ll transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to (i) the closing of an account of an individual, wherever located, who is not a blocked person (“the account holder”), held at a financial institution blocked pursuant to E.O. 14024, and (ii) the unblocking and lump sum transfer of all remaining funds and other assets in the account to the account holder, including to an account of the account holder held at a non-blocked financial institution, are authorized.’

Exceptions apply in both cases.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220819