Fact Sheet Preserving Agricultural Trade Access to Communication and Other Support to Those Impacted by Russia’s War Against Ukraine April 19 2022 In response to Russia’s unprovoked and brutal war against Ukraine the United States international partners and allies have imposed unprecedented economic costs on the Government of the Russian Federation and its supporters The U S Department of the Treasury’s Treasury Office of Foreign Assets Control OFAC is issuing this Fact Sheet to make clear that U S sanctions issued in response to Russia’s further invasion of Ukraine do not stand in the way of agricultural and medical exports nongovernmental organization NGO activities Coronavirus Disease 2019 COVID-19 relief the free flow of information humanitarian assistance and other support to people impacted by Russia’s war Beyond its toll on human life Russia’s war against Ukraine is causing significant harm in the region and the rest of the world Russian President Vladimir Putin’s unprovoked invasion of Ukraine is driving food and energy costs higher for people around the world His actions have disrupted supply chains of agricultural commodities destroyed agricultural and transportation infrastructure in Ukraine and put millions at increased risk of food insecurity Treasury is deeply concerned about the risks to global food supplies and food prices at a time when many emerging market and developing countries are still struggling to recover from the COVID-19 pandemic Treasury is working to address food security risks including bolstering social safety nets for the most vulnerable people unlocking trade finance to smooth disrupted supply chains for food and critical supplies strengthening countries’ domestic food production and addressing the macroeconomic impacts of the crisis on the most affected countries As the United States continues to impose sanctions on Russia for the atrocities being committed in Ukraine we reiterate our commitment to supporting activities that benefit the Ukrainian and Russian people and those around the world impacted by Russia’s further invasion of Ukraine These activities are not the target of our sanctions efforts and U S and non-U S persons can avail themselves of the authorizations exemptions and public guidance that the Treasury has issued as they continue to engage in these activities in relation to Ukraine and Russia These include the provision of basic foodstuffs and agricultural commodities humanitarian and other assistance by NGOs medicine and medical devices COVID-19 relief and telecommunications and internet services to support the flow of information As Treasury receives additional feedback OFAC will continue to evaluate the need for additional authorizations in support of people impacted by Russia’s war The information below is current and operative as of the date of publication of this Fact Sheet unless or until modified 1 1 This Fact Sheet is informational does not have the force of law and does not supersede the actual legal provisions cited Overview of Authorizations OFAC administers and enforces multiple authorities under which sanctions have been imposed on Russia including i the Russian Harmful Foreign Activities sanctions program established by the Russia-related national emergency declared in E O 14024 and subsequently expanded and addressed through certain additional authorities 2 and ii the Ukraine- Russia-related sanctions program established with the Ukraine-related national emergency declared in Executive Order E O 13660 and subsequently expanded and addressed through certain additional authorities 3 Pursuant to these sanctions programs numerous exemptions or authorizations exist to support the people of Ukraine and Russia as described in detail below Russian Harmful Foreign Activities Sanctions Program Treasury’s Russian Harmful Foreign Activities sanctions program is codified at 31 CFR part 587 Russian Harmful Foreign Activities Sanctions Regulations or RuHSR OFAC has issued many general licenses GLs under the Russian Harmful Foreign Activities sanctions authorities to authorize among other things humanitarian assistance agricultural and medical trade and other support to people impacted by Russia’s further invasion of Ukraine In all cases authorized transactions must comply with the terms and conditions set forth in the applicable GL and the below GLs only authorize activity prohibited by certain authorities Agricultural commodities medicine and medical devices Russia-related GL 6A “Transactions Related to the Exportation or Reexportation of Agricultural Commodities Medicine Medical Devices Replacement Parts and Components or Software Updates the Coronavirus Disease 2019 COVID-19 Pandemic or Clinical Trials ” authorizes certain transactions prohibited by the RuHSR that are ordinarily incident and necessary to 1 the exportation or reexportation of agricultural commodities medicine medical devices replacement parts and components for medical devices or software updates for medical devices to from or transiting the Russian Federation 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 that were in effect prior to March 24 2022 Telecommunications and internet-based communications Russia-related GL 25 “Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications ” authorizes certain transactions prohibited by the RuHSR that are ordinarily 2 The Russian Harmful Foreign Activities sanctions program represents the implementation of multiple legal authorities Some of these authorities are in the form of executive orders issued by the President E O s 14071 14068 14066 14039 and 14024 Other authorities are public laws statutes passed by Congress These authorities are further codified by OFAC in its regulations which are published in the Code of Federal Regulations CFR at 31 CFR part 587 Modifications to these regulations are posted in the Federal Register 3 The Ukraine- Russia-related Sanctions program represents the implementation of multiple legal authorities Some of these authorities are in the form of an executive order issued by the President E O s 14065 13849 13685 13662 13661 and 13660 Other authorities are public laws statutes passed by Congress These authorities are further codified by OFAC in its regulations which are published in the CFR at 31 CFR part 589 Modifications to these regulations are posted in the Federal Register 2 incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation as well as the exportation or reexportation sale or supply directly or indirectly from the United States or by U S persons to the Russian Federation of services software hardware or technology incident to the exchange of communications over the internet such as instant messaging videoconferencing chat and email social networking sharing of photos movies and documents web browsing blogging web hosting and domain name registration services NGO activities Russia-related GL 27 “Certain Transactions in Support of Nongovernmental Organizations’ Activities ” authorizes transactions ordinarily incident and necessary to the activities described below by NGOs that are prohibited by the RuHSR provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to E O 14024 • Activities to support humanitarian projects to meet basic human needs in Ukraine or the Russian Federation including drought and flood relief food nutrition and medicine distribution the provision of health services assistance for vulnerable or displaced populations including individuals with disabilities and the elderly and environmental programs • Activities to support democracy building in Ukraine or the Russian Federation including activities to support rule of law citizen participation government accountability and transparency human rights and fundamental freedoms access to information and civil society development projects • Activities to support education in Ukraine or the Russian Federation including combating illiteracy increasing access to education international exchanges and assisting education reform projects • Activities to support non-commercial development projects directly benefiting the people of Ukraine or the Russian Federation including related to health food security and water and sanitation and • Activities to support environmental and natural resource protection in Ukraine or the Russian Federation including the preservation and protection of threatened or endangered species responsible and transparent management of natural resources and the remediation of pollution or other environmental damage Personal remittances Russia-related GL 18 “Authorizing U S Dollar-Denominated Banknote Noncommercial Personal Remittances Prohibited by Executive Order of March 11 2022 ” authorizes certain transactions prohibited by the RuHSR that are ordinarily incident and necessary to the transfer of U S dollar-denominated banknote noncommercial personal remittances from i the United States or a U S person wherever located to an individual located in the Russian Federation or ii a U S person who is an individual located in the Russian Federation 3 Personal maintenance of U S individuals Russia-related GL 19 “Authorizing Transactions Related to Personal Maintenance of U S Individuals Located in the Russian Federation Prohibited by Executive Order of March 11 2022 ” authorizes individuals who are U S persons located in the Russian Federation to engage in certain transactions prohibited by the RuHSR that are ordinarily incident and necessary to their personal maintenance within the Russian Federation including payment of housing expenses acquisition of goods or services for personal use payment of taxes or fees and purchase or receipt of permits licenses or public utility services subject to certain conditions Emergency medical services Section 587 508 of the RuHSR authorizes the provision and receipt of nonscheduled emergency medical services U S government business Section 587 205 b of the RuHSR exempts transactions that are for the conduct of the official business of the U S government International organizations Section 587 205 b of the RuHSR exempts transactions that are for the conduct of the official business of the United Nations including its specialized agencies programs funds and related organizations UN by employees grantees or contractors thereof Additional activity related to the UN is also authorized by § 587 510 of the RuHSR In addition § 587 510 of the RuHSR authorizes transactions prohibited by the RuHSR that are for the conduct of the official business of the following entities by employees grantees or contractors thereof o The International Centre for Settlement of Investment Disputes ICSID and the Multilateral Investment Guarantee Agency MIGA o The African Development Bank Group the Asian Development Bank the European Bank for Reconstruction and Development and the Inter-American Development Bank Group IDB Group including any fund entity administered or established by any of the foregoing and o The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies Overflight payments emergency landings and air ambulance services Russia-related GL 7 “Authorizing Overflight Payments Emergency Landings and Air Ambulance Services ” authorizes transactions prohibited by E O 14024 that are ordinarily incident and necessary to the receipt of and payment of charges for services rendered in connection with overflights of the Russian Federation or emergency landings in the Russian Federation by aircraft registered in the United States or owned or controlled by or chartered to U S persons GL 7 also authorizes transactions prohibited by E O 14024 that are ordinarily incident and necessary to provide air ambulance and related medical services including medical evacuation to individuals in the Russian Federation Related FAQs 4 • FAQ 978 Guidance on permissible funds transfers involving sanctioned foreign financial institutions • FAQ 979 Guidance on transactions for official business of international organizations certain humanitarian-related trade or the response to the COVID-19 pandemic • FAQ 1025 Guidance on the impact of E O 14068 on GL 6 • FAQ 1028 Guidance on sending noncommercial personal remittances denominated in U S dollars to the Russia Federation Ukraine- Russia-related Sanctions Program The Ukraine- Russia-related sanctions program is codified in part at the Ukraine Related Sanctions Regulations 31 CFR part 589 The Ukraine- Russia-related sanctions program is a key tool in the U S government’s effort to disrupt and deter Russia’s malign activities stemming from Russia’s invasion of Ukraine in 2014 and to impose long-term costs on the Russian government for these activities While the Crimea region of Ukraine and the so-called Donetsk People’s Republic DNR and Luhansk People’s Republic LNR regions of Ukraine are blocked jurisdictions pursuant to E O s 13685 and 14065 respectively OFAC has issued many GLs under the Ukraine- Russiarelated sanctions program to authorize humanitarian assistance agricultural and medical trade and other support to people impacted by Russia’s malign activities In all cases authorized transactions must comply with the terms and conditions set forth in the applicable GL and only authorize activity prohibited by certain authorities Authorized activities involving the Crimea region of Ukraine While the Crimea region of Ukraine is comprehensively blocked pursuant to E O 13685 OFAC maintains several GLs designed to provide humanitarian relief and assistance to the Ukrainian people including transactions related to the export of food or medicine personal remittances telecommunications internet services and mail • Agricultural and medical exports Ukraine-related GL 4 “Authorizing the Exportation or Reexportation of Agricultural Commodities Medicine Medical Supplies and Replacement Parts ” authorizes certain transactions prohibited by E O 13685 that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities medicine medical supplies or replacement parts and components for medical supplies to the Crimea region of Ukraine or to persons in third countries purchasing specifically for resale to the Crimea region of Ukraine A list of authorized medical supplies can be found here • Personal remittances Ukraine-related GL 6 “Noncommercial Personal Remittances Authorized ” authorizes certain transactions prohibited by E O 13685 to send and receive and U S depository institutions U S -registered brokers or dealers in securities and U S -registered money transmitters are authorized to process transfers of funds to or 5 from the Crimea region of Ukraine or for or on behalf of an individual ordinarily resident in the Crimea region of Ukraine in cases in which the transfer involves a noncommercial personal remittance • Operation of Accounts Ukraine-related GL 7 “Operation of Accounts Authorized ” authorizes the operation of an account in a U S financial institution for an individual ordinarily resident in the Crimea region of Ukraine other than an individual whose property and interests in property are blocked pursuant to E O s 13660 13661 13662 or 13685 collectively the “Orders” provided that transactions processed through the account are of a personal nature and not for use in supporting or operating a business do not involve transfers directly or indirectly to the Crimea region of Ukraine or for the benefit of individuals ordinarily resident in the Crimea region of Ukraine unless authorized by Ukraine-related GL 6 “Noncommercial Personal Remittances Authorized” and are not otherwise prohibited by the Orders • Telecommunications and mail Ukraine-related GL 8 “Transactions Related to Telecommunications and Mail Authorized ” authorizes transactions prohibited by E O 13685 with respect to the receipt and transmission of telecommunications involving the Crimea region of Ukraine as well as certain transactions of common carriers incident to the receipt or transmission of mail and packages between the United States and the Crimea region of Ukraine • Internet-based communications Ukraine-related GL 9 “Exportation of Certain Services and Software Incident to Internet-Based Communications Authorized ” authorizes as otherwise prohibited by E O 13685 the exportation or reexportation directly or indirectly from the United States or by U S persons wherever located to persons in the Crimea region of Ukraine of certain services incident to the exchange of personal communications over the internet such as instant messaging chat and email social networking sharing of photos and movies web browsing and blogging as well as the export of software to enable such services Ukraine-related GL 9 also authorizes the exportation or reexportation directly or indirectly from the United States or by U S persons wherever located to persons in the Crimea region of Ukraine of software necessary to enable the certain services • Journalistic activities and establishment of news bureaus Ukraine-related GL 25 “Journalistic Activities and Establishment of News Bureaus in Certain Regions of Ukraine ” authorizes news reporting organizations that are U S persons and individuals who are U S persons regularly employed by a news reporting organization either as journalists including photojournalists or as supporting broadcast or technical personnel to engage in the certain transactions in the Crimea region of Ukraine that are ordinarily incident and necessary to their journalistic activities in said region see below for details on how this GL also applies to the DNR and LNR regions of Ukraine Related FAQs 6 o FAQ 453 Guidance on sending noncommercial personal remittances to or from the Crimea region of Ukraine o FAQ 454 Guidance on the export or reexport services or software with knowledge or reason to know that such services or software are intended for an individual or entity identified on the Sectoral Sanctions Identification List Authorized activities involving the so-called DNR and LNR regions of Ukraine While the DNR and LNR regions of Ukraine are comprehensively blocked pursuant to E O 14065 OFAC maintains several GLs designed to provide humanitarian relief and assistance to the Ukrainian people including transactions related to the export of food or medicine personal remittances telecommunications internet services mail and NGO activities • Agricultural and medical exports Ukraine-related GL 18 “Authorizing the Exportation or Reexportation of Agricultural Commodities Medicine Medical Devices Replacement Parts and Components or Software Updates to Certain Regions of Ukraine and Transactions Related to the Coronavirus Disease 2019 COVID-19 Pandemic ” authorizes transactions prohibited by E O 14065 that are ordinarily incident and necessary to 1 the exportation or reexportation of agricultural commodities medicine medical devices replacement parts and components for medical devices or software updates for medical devices to the DNR and LNR regions of Ukraine or to persons in third countries purchasing specifically for resale to the DNR and LNR regions of Ukraine or 2 the prevention diagnosis or treatment of COVID-19 including research or clinical studies relating to COVID-19 • Telecommunications and mail Ukraine-related GL 19 “Authorizing Transactions Related to Telecommunications and Mail ” authorizes transactions prohibited by E O 14065 related to telecommunications that are ordinarily incident and necessary to the receipt or transmission of telecommunications in the DNR and LNR regions of Ukraine as well as certain transactions of common carriers involving the DNR and LNR regions of Ukraine that are ordinarily incident and necessary to the receipt or transmission of mail and packages • Official business of international organizations Ukraine-related GL 20 “Official Business of Certain International Organizations and Entities ” authorizes transactions prohibited by E O 14065 for the conduct of the official business of certain international organizations and entities • Personal remittances and operation of accounts Ukraine-related GL 21 “Authorizing Noncommercial Personal Remittances and the Operation of Accounts ” authorizes certain transactions prohibited by E O 14065 that are ordinarily incident and necessary to the transfer of noncommercial personal remittances to or from the DNR and LNR regions of Ukraine or for or on behalf of an individual ordinarily resident in the DNR and LNR regions of Ukraine Further Ukraine-related GL 21 authorizes certain transactions that are ordinarily incident and necessary to maintaining operating or closing an account of an individual ordinarily resident in the DNR and LNR regions of Ukraine U S 7 depository institutions U S -registered brokers or dealers in securities and U S registered money transmitters are authorized to process noncommercial personal remittances pursuant to Ukraine-related GL 21 regardless of whether the originator or beneficiary is an individual who is a U S person GL 21 is not limited to a specific method of payment • Internet-based communications Ukraine-related GL 22 “Authorizing the Exportation of Certain Services and Software Incident to Internet-Based Communications ” authorizes as otherwise prohibited by E O 14065 the exportation or reexportation directly or indirectly from the United States or by U S persons wherever located to persons in the DNR and LNR regions of Ukraine of certain services incident to the exchange of personal communications over the internet such as instant messaging chat and email social networking sharing of photos and movies web browsing and blogging as well as the export of software to enable such services Ukraine-related GL 22 also authorizes the exportation or reexportation directly or indirectly from the United States or by U S persons wherever located to persons in the DNR and LNR region of Ukraine of software necessary to enable certain services • NGO activities Ukraine-related GL 23 “Certain Transactions in Support of Nongovernmental Organizations’ Activities ” authorizes certain transactions prohibited by E O 14065 that are ordinarily incident and necessary to the support of NGO activities in the DNR and LNR regions of Ukraine including activities related to humanitarian projects to meet basic human needs democracy building education non-commercial developments projects and environmental and natural resource protection Such transactions may include the processing and transfer of funds payment of taxes fees and import duties and purchase or receipt of permits licenses or public utility services • Civil maritime services Ukraine-related GL 24 “Transactions Related to the Provision of Maritime Services ” authorizes transactions related to the provision or receipt of civil maritime services performed by individuals who are ordinarily resident in the DNR or LNR regions of Ukraine provided that such services are performed outside the DNR and LNR regions of Ukraine and such services are not performed on behalf of any entity located in or organized under the laws of the DNR and LNR regions of Ukraine • Journalistic activities and establishment of news bureaus Ukraine-related GL 25 “Journalistic Activities and Establishment of News Bureaus in Certain Regions of Ukraine ” authorizes news reporting organizations that are U S persons and individuals who are U S persons regularly employed by a news reporting organization either as journalists including photojournalists or as supporting broadcast or technical personnel to engage in certain transactions in the DNR and LNR regions of Ukraine that are ordinarily incident and necessary to their journalistic activities in said regions see above for details on how this GL also applies to the Crimea region of Ukraine Related FAQs 8 • FAQ 1007 Guidance on authorized activities with the DNR and LNR regions of Ukraine Additional Licensing For transactions neither exempt nor authorized by OFAC OFAC considers specific license requests on a case-by-case basis and prioritizes license applications and other requests for guidance that are related to humanitarian activity Please see OFAC’s License Application Page for additional details regarding the specific licensing process Additional Information If you have additional questions we encourage you to contact the OFAC Compliance Hotline at 1-800-540-6322 or email OFAC_Feedback@treasury gov As with specific license requests OFAC prioritizes answering questions that are related to humanitarian activity 9