Under Executive Order 14024, Directive 4, the Director of the Office of Foreign Assets Control (OFAC) and the Department of State have made the official decision to prohibit transactions that involve:

  • The Central Bank of the Russian Federation
  • The National Wealth Fund of the Russian Federation
  • The Ministry of Finance of the Russian Federation

This prohibition includes any transfer of assets to these entities or any foreign exchange transaction for or on behalf of listed entities. It also prohibits any transaction that evades or avoids, causes a violation of, or attempts to violate any of the prohibitions listed above and in Directive 4.

On January 6, 2026, the OFAC issued a revised GL 13P, which became effective immediately and will remain in effect up until 12:01 A.M. EST on April 9, 2026. GL 13 P authorizes certain administrative transactions that otherwise would be considered prohibited under Directive 4. 

More specifically, it allows U.S. citizens or entities to pay fees, remit taxes, settle import duties, purchase permits, receive licenses, register with, and receive certificates from Directive 4 entities. These allowances are only legal when the transactions are ordinarily incident and necessary to the person’s day-to-day operations in the Russian Federation.

It’s important for each individual to strictly scrutinize each transaction they make, especially if it involves one of the Directive 4 entities, to avoid potential criminal and civil penalties. In some cases, it might be necessary to take additional action to remain compliant with the law. For instance, U.S. individuals who own a divestment of assets in the Russian Federation and need to pay exit taxes are not free to do so under the revised GL 13P. 

The reason for this is that payment of exit taxes isn’t considered ordinarily incident and necessary to the day-to-day operations in the Russian Federation. If a U.S. citizen needs to pay these exit taxes, then they need to seek out a specific license from the OFAC to legally do so. The OFAC’s Licensing Division will then review the situation in-depth. Each request is evaluated on a case-by-case basis. 

Once a decision is made, the taxpayer will be informed about how they should proceed with either payment or non-payment.

How to Stay Advised on International Transactions and OFAC Sanctions

One of the most complicated parts of international business is accounting for the various local, state, federal, national, and international laws that could impact your dealings. Staying up to date with the latest OFAC sanctions and legal changes requires significant research and time, but it’s necessary to remain compliant.

Violating OFAC sanctions could result in criminal charges and civil consequences, like serious monetary fines.

Here at Bukh Global, our team of experienced lawyers can help you and your business better understand OFAC’s current sanction laws and your obligations as a company. To schedule a free phone call about your business’s needs, leave your contact details on our online form.