OFAC Publication of Ukraine-/Russia-Related General Licenses 17–25

Mechanism

The August 2022 Federal Register publication formalised nine GLs that OFAC had been posting directly to its website since February–March 2022, when the Biden administration designated the Donetsk and Luhansk "People's Republics" and substantially extended the Crimea-related EO 13685 framework via EO 14065. The FR publication does not alter any GL's substantive scope; it is an administrative codification step required by the Administrative Procedure Act and Treasury practice.

GL 17 — DNR/LNR wind-down (expired): Issued 21 February 2022, authorised a 30-day wind-down window (until 23 March 2022 at 12:01 a.m. EDT) for existing Donetsk- and Luhansk-area transactions, contracts, and divestiture operations. By the time of the FR publication, this GL had been expired for more than four months.

GL 18 — Agricultural commodities, medicine, medical devices, and COVID-19: Authorises the exportation or re-exportation of agricultural commodities, medicine, and medical devices (including replacement parts, components, and software updates) to the Covered Regions and transactions related to the COVID-19 pandemic. Mirrors the cross-program humanitarian carve-out OFAC has applied to most country sanctions programmes.

GL 19 — Telecommunications and mail: Authorises transactions ordinarily incident to the receipt and transmission of telecommunications involving the Covered Regions, and the receipt or transmission of mail.

GL 20 — Official international organisation business: Authorises transactions involving the United Nations and its programmes and specialised agencies, the International Committee of the Red Cross, the International Federation of Red Cross and Red Crescent Societies, and other listed international organisations conducting official business in the Covered Regions.

GL 21 — Remittances and personal accounts: Authorises noncommercial, personal remittances to ordinary residents of the Covered Regions and the operation of accounts held by such individuals at US financial institutions, subject to transaction-size limits.

GL 22 — Internet-based communications: Authorises the exportation of certain services (hosting, back-end infrastructure, translation, moderation) and software ordinarily incident to personal communications over the internet to the Covered Regions.

GL 23 — NGO activities: Authorises transactions in support of nongovernmental organisations' disaster-relief, health, democracy-promotion, education, environmental, and peacebuilding activities. Explicitly excludes knowing fund transfers to blocked persons not meeting specified criteria.

GL 24 — Civil maritime services: Authorises transactions related to the provision of civil maritime services by individuals ordinarily resident in the Covered Regions, provided the services are performed outside those regions. Does not authorise new investment in the Covered Regions or transactions with SDN-listed persons.

GL 25 — Journalistic activities: Authorises news-reporting organisations and journalists (including photojournalists) and their support staff (stringers, translators, camera operators) to engage in transactions necessary for journalistic activities in Crimea, the DNR, and the LNR. Issued under both EO 14065 and EO 13685.

Downstream implications

• The DNR/LNR carve-outs largely mirror pre-existing Crimea GLs under EO 13685, creating a

structurally consistent framework for all Russian-controlled Ukrainian territory at the time.

• The formal FR codification reduces legal ambiguity for banks, shippers, and NGOs operating under

these licenses — clearing an obstacle to humanitarian disbursement that web-only posting had created.

• GL 25 (journalism) is notable: it is broader than the Crimea journalism GL it extends, explicitly

covering support staff compensation, which had been a point of uncertainty for international news bureaus.

• The framework was largely superseded by the broader EO 14024 Russia-wide sanctions architecture

but continues to govern specifically Crimea/DNR/LNR transactions to the extent they remain legally distinct.

Open questions

• Whether GLs 18–25 have since been amended or revoked as subsequent Russia-wide GLs (e.g.,

EO 14024 humanitarian GLs) effectively absorbed their scope.

• Status of GL 23 (NGOs) in practice given the 2022–24 escalation of financial-crime enforcement

around Russian-adjacent payments.