OFAC General License 13P: Limited Authorization for Transactions with Russia

On January 6, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 13P (GL 13P), introducing a temporary authorization for certain transactions that are otherwise prohibited under Directive 4 of Executive Order 14024. This development reflects the continued evolution of U.S. sanctions policy toward Russia, balancing restrictive measures with limited operational flexibility.

Under GL 13P, U.S. persons are authorized to carry out specific transactions related to taxes, duties, customs payments, and import fees, even when these involve key Russian financial institutions such as the Central Bank of Russia, the National Wealth Fund, or the Russian Ministry of Finance. These types of transactions are typically restricted under existing sanctions frameworks, making this authorization a targeted exception designed to address practical administrative needs.

The license is valid through April 6, 2026, providing a defined window during which these transactions may legally occur. This temporary nature underscores the controlled and conditional approach adopted by U.S. authorities, allowing limited interactions without weakening the broader sanctions regime.

In parallel, OFAC also updated its Specially Designated Nationals (SDN) List by removing three individuals previously designated under the Russia sanctions program. While limited in scope, this update illustrates the dynamic nature of sanctions enforcement, where listings can evolve based on policy, legal, or diplomatic considerations.

Overall, General License 13P highlights the increasingly nuanced structure of U.S. sanctions. While financial pressure on Russia remains firmly in place, certain transactions considered essential for administrative and fiscal continuity are selectively authorized. For companies, this reinforces the importance of closely monitoring regulatory updates and ensuring that any reliance on general licenses is carefully assessed, documented, and compliant with the precise scope of the authorization.