On April 7, the U.S. Office of Foreign Assets Control (OFAC) issued a new General License No. 25 (GL25) authorizing certain transactions ordinarily incident to telecommunications and the exchange of communications over the internet in Russia.
GL25 authorizes U.S. persons to engage in transactions that are ordinarily incident and necessary to the to the receipt or transmission of telecommunications involving Russia that are prohibited by OFAC’s Russian Harmful Foreign Activities Sanctions Regulations (31 C.F.R. Part 587), subject to the limitations specified in the license.
GL25 also authorizes U.S. persons to provide services, software, hardware, or technology to Russia incident to the exchange of communications over the internet that would otherwise be prohibited by Part 587. Qualifying services include instant messaging, videoconferencing, chat and email, social networking, sharing of photos, movies, and documents, web browsing, blogging, web hosting, and domain name registration services.
GL25 does not authorize the opening or maintaining of a correspondent account or payable-through account prohibited under Directive 2 to E.O. 14024; debits to the accounts of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; or transactions that are prohibited by Executive Orders 14066 or 14068. Note that GL25 does not relieve exporters from separate licensing obligations governing exports and reexports of goods, software, and technology to Russia under U.S. export control rules, including the Export Administration Regulations.
U.S. and global companies that provide telecommunications and internet communications services to Russia should carefully review the scope of the authorized activities for potential application to their business.