Financial sanctions, Russia

On June 28, 2023, the HM Treasury’s Office of Financial Sanctions Implementation, OFSI, published a new document in connection with Russia-related sanction measures. Specifically, the Office published a new „Fact Sheet“ entitled „Humanitarian Assistance and Food Security Fact Sheet: Understanding UK and U.S. Sanctions and their Interconnection with Russia“. The Fact Sheet which actually consists of several frequently asked questions (FAQs) addresses various aspects relating to humanitarian aid and commodity-related transactions involving the Russian Federation, including
– exceptions for Non-Government Organizations (NGOs) and international organizations providing humanitarian assistance,
– transactions involving agricultural commodities, medicine, and medical devices, and
– transactions involving the Russian Agricultural Bank.
The key covered questions are the following – as quoted; for the answers, please refer to the original legal document:
1. Do U.S. and UK sanctions targeting Russia provide exceptions for non-government organisations (NGOs) or international organizations (IOs) providing humanitarian assistance?
2. Can U.S. and UK financial institutions process transactions related to the exportation of agricultural commodities, medicine, or medical devices to, from, transiting, or related to Russia?
3. Can U.S. and UK financial institutions process transactions involving Joint Stock Company Russian Agricultural Bank (Russian Agricultural Bank) related to the exportation of agricultural commodities to, from, transiting, or related to Russia?
The Fact Sheet also provides tables with
– existing provisions for the exemption of humanitarian aid and commodity-related transactions from sanction provisions in both U.S. and UK legislation and
– existing guidance and FAQs in this context.