OFAC AMENDS UKRAINE-RELATED SANCTIONS REGULATIONS AND ANNOUNCES OTHER SANCTIONS RELATED UPDATES
June 17, 2022
On May 2, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a Final Rule in the Federal Register to announce its plans to amend the heading of the Ukraine Related Sanctions Regulations to the “Ukraine-Russia-Related Sanctions Regulations,” and replacing the Ukraine-related sanctions regulations that were previously published in abbreviated form on May 8, 2014 with a more comprehensive set of regulations that includes additional interpretive and definitional guidance, general licenses, and other regulatory provisions to provide further guidance to the public. The Reissued Regulations are generally connected to U.S. sanctions targeting Russia that were implemented in 2014 and are separate from the Russian Harmful Foreign Activities Sanctions Regulations detailed in 31 C.F.R. Part 587 that implement Executive Order (“EO”) 14024 and the recent Russia-related Orders issued in 2022. OFAC stated that because of the number of regulatory sections being updated or added, it decided to reissue the Regulations in their entirety. Specifically, the amendment includes implementation of the Ukraine-/Russia-related Executive order of December 19, 2014, and provisions of the Ukraine Freedom Support Act of 2014, the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014, and the Countering America’s Adversaries Through Sanctions Act. In addition, OFAC announced that the amendment would incorporate four directives regarding sectoral sanctions issued pursuant to the Ukraine-/Russia-related Executive order of March 20, 2014, and six general licenses that had previously only appeared on its website, as well as seven new general licenses.
Later in the month on May 12, 2022, OFAC issued Syria General License 22, which authorizes activities that are ordinarily incident and necessary to activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria including information and telecommunications, power grid infrastructure, construction, finance, transportation and warehousing, manufacturing, and trade, to name a few. The general license does not authorize any transactions involving any person, including the Government of Syria, whose property or interests in property are blocked pursuant to the SySR or the Caesar Syria Civilian Protection Act of 2019. In the same notice, OFAC also announced its intent to publish several new Frequently Asked Questions (“FAQs”) related to U.S. sanctions on Syria.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com 202-659-6622) or Drew Derco (dderco@eckertseamans.com 202-659-6665).
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