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OFAC releases food safety fact sheet on Russian sanctions and agricultural trade

The United States Department of the Treasury (Treasury) has released a fact sheet stating that it has not imposed sanctions on the production, manufacture, sale or transportation of agricultural products (including fertilizers) , agricultural equipment or medicines relating to the Russian Federation (Russia).

In addition, the Treasury’s Office of Foreign Assets Control (OFAC) has issued a Broad General License (GL) to authorize certain transactions related to agricultural products, agricultural equipment, drugs and medical devices, according to a statement released Thursday.

The United States strongly supports United Nations efforts to bring Ukrainian and Russian grain to world markets and to reduce the impact of Russia’s unprovoked war against Ukraine on world food supplies and prices, says the press release.

“The agricultural and medical trade is not the target of US sanctions imposed on Russia for its atrocities in Ukraine,” he added.

The U.S. Department has released the “Fact Sheet: Preserving Agricultural Trade, Access to Communication, and Other Support to those Impacted by Russia’s War Against Ukraine” for details on U.S. sanctioned clearances related to agricultural and medical transactions, NGOs, to Covid-19 relief, free flow of information, humanitarian aid and other forms of support to people affected by the war in Russia.

The United States has not imposed sanctions on the export of agricultural products from, to or involving Russia, according to the fact sheet.

In addition, to the extent that transactions related to the export of agricultural products from, to or involving Russia may otherwise be prohibited by Russia’s Harmful Foreign Activities Sanctions Regulations (RuHSR), OFAC has issued a GL 6B related to Russia to authorize certain transactions related to the production, manufacture, sale or transportation of agricultural products and agricultural equipment, among other products and activities.

The United States has banned the importation of fish, seafood and their preparations originating in the Russian Federation into the United States. However, the ban does not limit the import of fish, seafood and their preparations originating in the Russian Federation from Russia to countries other than the United States.

Executive Order 14068 prohibits the importation into the United States of fish, seafood and their preparations, alcoholic beverages, and non-industrial diamonds originating in the Russian Federation, the statement said.

However, to the extent that the importation of these Russian-origin products into jurisdictions outside the United States does not involve a sanctioned person or otherwise prohibited transaction, non-U.S. persons are not subject to sanctions in under the order. In addition, GL 6B allows certain transactions related to the export of fish, seafood and their preparations originating in the Russian Federation, provided that such transactions do not involve the import of such goods originating in the Russian Federation. Russia in the United States.

Additionally, the United States has not imposed sanctions on the export of fertilizers from, to, in transit to, or involving Russia.

Therefore, it is not prohibited to provide insurance or reinsurance related to the transportation or shipment of these products. To the extent that transactions relating to such insurance or reinsurance services may otherwise be prohibited by the RuHSR.

The United States also did not impose general sanctions on the export of agricultural equipment and spare parts to Russia. To the extent that transactions related to the export of agricultural equipment and parts to Russia may otherwise be prohibited by the RuHSR, GL 6B permits certain transactions related to agricultural equipment. Additionally, Russia-related GL 41, “Authorization of Certain Transactions Related to Agricultural Equipment,” authorizes transactions related to agricultural equipment, components, or spare parts produced by certain blocked Russian persons.

The US Treasury Department said in its statement that the port of Novorossiysk is not on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) and is not subject to blocking sanctions under of the RuHSR or any other US sanctions authority. To the extent that transactions involving the export of products from the port of Novorossiysk may otherwise be prohibited by the RuHSR, GL 6B permits certain transactions related to agricultural products, agricultural equipment, medicines, medical devices, parts and components of replacement for medical devices or software updates. for medical devices, as well as transactions related to the prevention, diagnosis or treatment of Covid-19 (including research or clinical studies relating to Covid-19), or ongoing clinical trials. This would include the export of these products from the port of Novorossiysk.

Foreign financial institutions may engage in or facilitate transactions that would be permitted for US Persons under GL 6B without incurring sanctions.

Additionally, the Joint Stock Company Russian Agricultural Bank is not listed on OFAC’s SDN list. It is not subject to blocking sanctions under the RuHSR or any other US sanctions authority. However, US persons are subject to certain restrictions on trading in debt and shares of the Russian Agricultural Bank. U.S. Persons involved in a transaction where Russian Agricultural Bank is a counterparty must ensure that the payment terms provided to Russian Agricultural Bank comply with these restrictions on trading its debt and equity.

Specifically, the Agricultural Bank of Russia is subject to Directive 3 under the “Prohibitions on New Borrowing and Equity Participation by Certain Russian-Related Entities” (Russia-Related Entity Directive). The directive prohibits, among other things, transactions and dealings by U.S. persons or inside the United States in new debt with a maturity of more than 14 days or in new equity of the Russian Agricultural Bank when these new debts or new equity are issued at 12:01 or later. am Eastern Daylight Time on March 26, 2022.

The Agricultural Bank of Russia is also subject to Directive 1 under EO 13662, § 589.202 of the Ukraine-Russia Sanctions Regulations. The prohibitions in § 589.202 apply only to certain transactions in new debts or shares of the Russian Agricultural Bank.

The U.S. Department encouraged anyone with specific questions about transactions involving the Russian Agricultural Bank to contact OFAC’s Compliance Hotline at 1-800-540-6322 or by email. [email protected]