New OFAC General License Clarifies Ability to Engage in Humanitarian Aid in Ukraine and Russia
In connection with the war in Ukraine, the United States has significantly enhanced its sanctions against the Russian Federation. However, the Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) recently issued a new General License, General License No. 27, which clarifies that the sanctions do not apply to certain humanitarian work in Ukraine and the Russian Federation. Thus, nongovernmental organizations (“NGOs”) (including 501(c)(3) nonprofit charitable organizations) may engage in certain activities, either directly or by transferring funds in support, that would otherwise be prohibited under the sanctions.