Publication of Russian Harmful Foreign Activities Sanctions Regulations Web General License 104A
Summary
This regulation allows certain limited transactions with Russian entities that would normally be banned due to harmful activities. The U.S. Treasury Department created a special license to permit specific business dealings while maintaining overall sanctions against Russia.
Key Points
- 1The Treasury Department (OFAC) issued General License 104A to permit certain otherwise-prohibited transactions involving Russian entities
- 2This license creates narrow exceptions to broader Russian sanctions imposed due to harmful foreign activities
- 3Businesses and individuals must still follow strict rules and may only conduct transactions that fall under the specific terms of this license
- 4Companies engaged in permitted transactions must maintain detailed records and comply with all reporting requirements
- 5Unauthorized transactions with Russian entities remain illegal and subject to significant penalties
Impact Assessment
If you are a Financial Institution or Importer/Exporter, this means you may conduct specific authorized transactions with Russian entities under General License 104A that would otherwise be prohibited, requiring careful documentation and compliance monitoring to ensure transactions fall within the license parameters.
International
Moderate
Key Dates
October 1, 2025
Regulatory Connections
Transnational Criminal Organizations Sanctions Regulations Web General License 1
Russian Harmful Foreign Activities Sanctions Regulations Web General License 129
Russian Harmful Foreign Activities Sanctions Regulations Web General License 13O
Russian Harmful Foreign Activities Sanctions Regulations Web General License 132
This summary is for informational purposes only. It may not capture all nuances of the regulation. Always refer to the official text for authoritative information.