Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

On 4 August 2022 OFAC formally published in the Federal Register nine general licenses (GLs 17–25) that had previously been made available only on OFAC's website under EO 14065 (Donetsk/Luhansk regions) and, for GL 25, also EO 13685 (Crimea). GL 17, which authorised wind-down of Donetsk/Luhansk transactions, had already expired on 23 March 2022. GLs 18–25 remain in force and authorise a structured set of humanitarian and civil-society carve-outs — covering agricultural commodities, medicine and medical devices, telecommunications, official international organisation business, personal remittances, internet-based communications, NGO activities, civil maritime services, and journalistic activities — within the otherwise restricted territory of Crimea, the so-called Donetsk People's Republic (DNR), and the Luhansk People's Republic (LNR).

On 13 July 2022 OFAC formally published in the Federal Register two general licenses (GL 2 and GL 10) that had been issued under the Ukraine-/Russia-Related Sanctions program and made available previously only on OFAC's website. Both licenses had already expired by the time of publication: GL 2 (EO 13662 Directive 4 wind-down, expired September 2014) authorised a limited window to wind down contracts involving Russian energy-sector entities subject to sectoral sanctions, while GL 10 (EO 13685 Crimea, expired October 2016) authorised divestiture of holdings in blocked Russian infrastructure entity PJSC Mostotrest. The Federal Register codification is an administrative archival step with no substantive change to the sanctions regime.

On 27 May 2022 OFAC formally published in the Federal Register two general licenses (GL 13Q and GL 13R) that had been issued under the Ukraine-/Russia-Related Sanctions program and previously made available only on OFAC's website. Both licenses had already expired by the time of FR publication: GL 13Q (issued 24 Jan 2022, expired 27 Apr 2022) authorised the divestiture or transfer of debt, equity, or other holdings in GAZ Group to a non-US person; GL 13R (issued 25 Apr 2022, expired 25 May 2022) superseded GL 13Q and continued the wind-down authorisation for a further 30 days. The Federal Register publication is an administrative archival step with no substantive change to the active sanctions regime; both GLs were expired at time of codification.

On 27 May 2022 OFAC formally published in the Federal Register two general licenses (GL 15K and GL 15L) issued under the Ukraine-/Russia-Related Sanctions program. Both licenses had already expired by the time of Federal Register publication. GL 15K (effective 24 Jan 2022, expired 27 Apr 2022) authorised a broad set of manufacturing, sales, and operational transactions involving GAZ Group and its majority-owned subsidiaries; GL 15L (effective 25 Apr 2022, expired 25 May 2022) superseded GL 15K and narrowed authorisation to wind-down transactions only, while explicitly prohibiting new debits to GAZ Group accounts at US financial institutions. The FR publication is an administrative archival step codifying web-published licences after their operative windows had already closed.

On 2 March 2022 the Council of the European Union adopted Regulation (EU) 2022/355, amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus. It bans importing, purchasing or transporting products originating in or exported from Belarus in wood (Annex X), cement (Annex XI), iron and steel (Annex XII) and rubber (Annex XIII), and extends restrictions to potassium chloride ("potash"), tobacco and mineral products, plus a ban on exporting dual-use goods, machinery (Annex XIV) and goods usable for Belarus's military or security development. The measure responds to Belarus's active facilitation of Russia's invasion of Ukraine. It entered into force the day after publication in the Official Journal (OJ L 67, 2 March 2022), i.e. 3 March 2022, with a wind-down period to 4 June 2022 for pre-existing contracts.

OFAC codified the Chinese Military-Industrial Complex Sanctions Regulations at 31 CFR Part 586, implementing Executive Order 13959 (November 12, 2020) as amended by Executive Order 14032 (June 3, 2021). The regulations prohibit US persons from purchasing or selling publicly traded securities of entities designated on OFAC's Non-SDN Chinese Military-Industrial Complex Companies (NS-CMIC) List, which identifies firms determined to support the People's Liberation Army or Chinese surveillance-technology programs. A divestment deadline of June 3, 2022 applied to entities named in the original EO 13959 annexes; future additions carry a one-year divestment window from the date of designation.