OFAC Eases Certain Sanctions Involving Russia's FSB; BIS Licensing Still Required.

 
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On February 2, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Cyber-related General License (GL) 1, a general license that authorizes certain transactions with Russia's Federal Security Service (Federalnaya Sluzhba Bezopasnosti or FSB). GL 1 authorizes U.S. persons (i.e., individuals and companies) to request, receive, use, pay for or deal in licenses, permits, certifications, or notifications issued or registered by the FSB for information technology (IT) products in Russia, provided that (i) the relevant IT goods or technology are subject to the U.S. Export Administration Regulations (EAR) and are licensed or otherwise authorized by the U.S. Department of Commerce's Bureau of Industry and Security (BIS); and (ii) payment of fees to the FSB for such licenses and other authorization or notification does not exceed $5,000 in any calendar year. GL 1 also authorizes transactions or activities that are necessary and ordinary incident to complying with law enforcement or administrative actions or investigations involving the FSB or rules and regulations administered by the FSB.

GL 1 is a technical fix to earlier sanctions restrictions imposed by OFAC on the FSB in December 2016 in response to Russia's alleged cyber-related interference in the 2016 U.S. elections. Please see our previous client alert here. OFAC issued GL 1 in response to complaints from U.S. companies that were unable to import many consumer technology products into Russia without a permit from the FSB, Russia's principal security agency.

GL 1 does not authorize the exportation, reexportation or provision of goods, technology or services to the Crimea region of Ukraine....

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