On April 7, the US Office of Foreign Assets Control (OFAC) issued a new General License No. 25 (GL25) that authorizes certain transactions normally related to telecommunications and the exchange of communications through the Internet in Russia.
GL25 authorizes U.S. persons to engage in transactions that are ordinarily incidental to and necessary for the receipt or transmission of telecommunications involving Russia that are prohibited by the OFAC Russian Harmful Foreign Activity Sanctions Regulations (31 CFR Part 587), subject to the limitations specified in the license.
GL25 also authorizes US persons to provide services, software, hardware, or technology to Russia in connection with the exchange of communications over the Internet that would otherwise be prohibited by Part 587. Services that Qualifying services include instant messaging, video conferencing, chat and email, social networking, photo, movie and document sharing, web browsing, blogging, web hosting and domain name registration services.
GL25 does not authorize the opening or maintenance of a correspondent account or payment account prohibited under Directive 2 to EO 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. Please note that GL25 does not exempt exporters from separate license obligations governing exports and re-exports of goods, software and technology to Russia under export control rules of the USA, including the Export Administration Regulations.
US and global companies providing telecommunications and Internet communications services to Russia should carefully review the scope of authorized activities for possible application to their businesses.