US Has Authorized Provision of Accounting, Trust and Corporate Formation, and Management Consulting Services to Russian Persons in Spheres of Agricultural Commodities and Medicine

30 January 2023
Ellina Izotkina
Senior Associate
Julia Kuzmenko
Senior Associate

The new General license No 6C published by OFAC on January 1, 2023, establishes exceptions from US sanctions related to the spheres of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices.

Previously under General license No 6 of February 24, 2022, General license No 6A of March 24, 2022 and General license No 6B of July 14, 2022, transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (E.O. 14024) related to: (1) the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or (3) ongoing clinical trials and other medical research activities were authorized.

With the General license No 6C an exception has also been made for exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, or management consulting services to any person located in the Russian Federation, when used in the spheres mentioned.

General license No 6C does not affect other prohibitions under E.O. 14066, E.O. 14068, or E.O. 14071. For instance, processing transactions related to correspondent or payable-through accounts of sub-sanctioned Russian entities and involving certain Russian financial institutions is still prohibited.