The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has recently updated its Russia General License (GL) 25E, maintaining authorisation for essential and incidental transactions to telecommunications involving the Russian Federation. That license facilitates various internet-based services, including instant messaging, social networking, and e-learning platforms.
It supports the ongoing exchange of communications and allows for the export or reexport of related software, hardware, and technology, provided such transactions comply with the Department of Commerce’s Export Administration Regulations. However, it is important to note that transactions involving significant Russian telecommunications companies designated by OFAC remain unauthorised under this license and must be carefully analysed.
The Department of the Treasury’s Office of Foreign Assets Control has also issued a critical alert regarding Russia’s attempts to evade sanctions by establishing new overseas branches and subsidiaries of Russian financial institutions. That alert warns that these efforts to open new international branches or subsidiaries should be considered potential red flags for sanction evasion.
Financial institutions and foreign regulators are advised to exercise caution when engaging with these entities, as activities such as maintaining accounts, transferring funds, or providing financial services may carry significant risks of facilitating Russia’s attempts to bypass sanctions.