OFAC Publication of Ukraine-/Russia-Related General Licenses 2 and 10

Mechanism

The July 2022 Federal Register publication is an administrative codification of two expired general licenses that OFAC had originally issued years earlier under separate Ukraine-related Executive Orders. The publication creates an official Federal Register record for regulatory completeness but does not extend, revive, or modify either GL.

GL 2 — EO 13662 Directive 4 wind-down (expired September 2014): Issued 12 September 2014 under Executive Order 13662, GL 2 authorised a 14-day window (until 26 September 2014 at 12:01 a.m. EDT) to wind down contracts and operations involving persons subject to Directive 4 of the Ukraine-related sectoral sanctions. Directive 4 targeted Russia's deepwater, Arctic offshore, and shale oil exploration and production sector. GL 2 did not authorise any new provision, exportation, or re-exportation of goods, services, or technology — only the minimum activity needed to cease existing Directive 4-related transactions. By the FR publication date, GL 2 had been expired for nearly eight years.

GL 10 — EO 13685 Crimea divestiture (expired October 2016): Issued 31 August 2016 under Executive Order 13685, GL 10 authorised US and non-US persons to divest or transfer holdings in PJSC Mostotrest — a Russian infrastructure and bridge-construction company designated under EO 13685 for its operations in Crimea — to a non-US person, and to facilitate, clear, and settle such divestiture transactions. The authorisation window closed 1 October 2016 at 12:01 a.m. EDT. By the FR publication date, GL 10 had been expired for nearly six years.

Downstream implications

• Both GLs pre-date the post-February 2022 Russia sanctions escalation architecture (EO 14024,

EO 14065) and represent an earlier, narrower sanctions era.

• The FR codification is a housekeeping measure consistent with Treasury's Administrative

Procedure Act obligations; it has no operative effect on the current Russia/Ukraine-related sanctions perimeter.

• PJSC Mostotrest's designation status and any subsequent changes would be governed by the broader

EO 13685 and EO 14024 frameworks, not by the expired GL 10.

• GL 2's Directive 4 context (sectoral energy-sector restrictions) was eventually subsumed by the

much broader post-2022 Russia sanctions architecture, including sector-wide blocking of Russian energy entities.

Open questions

• Whether Mostotrest has since been re-designated or had its status modified under EO 14024 SDN

framework as part of the broader Russia escalation.

• Whether OFAC plans further archival FR publications for other early Ukraine-/Russia-related GLs

issued between 2014 and 2022 that remain only on the OFAC website.