U.S. Issues Clarifications on Sanctions and Additional Measures to Facilitate Global Food Security
Washington, D.C. (July 19, 2022) - Reacting to concerns that U.S. sanctions could be viewed as impeding exports or global transactions related to urgently needed food, fertilizer, agricultural equipment, or medical supplies, on July 14, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a fact sheet clarifying that “agricultural and medical trade are not targets” of U.S. sanctions. In addition to providing these assurances to banks, shippers, and insurance companies, the OFAC measures include a new General License 6B, which explicitly authorizes transactions related to (1) the production, manufacturing, sale, or transport of agricultural commodities and equipment, (2) medicine, medical devices and components, parts, or associated software, (3) medical research and clinical trials, and (4) medical efforts in furtherance of COVID-19 prevention, diagnosis, or treatment. Further, OFAC issued a new General License 44 authorizing U.S. persons to provide tax preparation or tax filing services to U.S. persons located in Russia.
The new OFAC publication serves as a reminder of the far-reaching implications of the sanctions put in place by the U.S. and other countries on Russia, and the complicated questions these restrictions may raise for businesses operating in the global market. Concerns about potential impacts on shipments needed for international food security were widely voiced by banks, insurers, and shipping companies, and a May 31, 2022 statement from the U.S. Representative to the United Nations, Ambassador Linda Thomas-Greenfield, that companies could seek “comfort letters” did not alleviate these fears.
Lewis Brisbois’s attorneys are advising clients on the increasingly complex and quickly-evolving issues relating to the imposition of sanctions on Russian entities, and are available to provide assistance on compliance and management of business and legal risks. For more information, contact the authors of this alert. Visit our Ukraine Conflict Response Practice page for more alerts in this area.
Jane C. Luxton, Managing Partner - Washington, D.C.
Andrew Pidgirsky, Partner