Russian sanction exemptions, 2020

Publisher: US Department of the Treasury Start Date: 2018 End Date: 2020 Record Count: None

Collection: Compliance
Description:

This is "a listing of the licenses granted, from Jan 1, 2018 and May 1, 2020" to "do business in or with parties under the Ukraine, Russian and sanctions programs, including CAATSA" from the U.S. Treasury Department's Office of Foreign Assets Control. These are businesses that have been given permission to ignore sanctions in certain circumstances--but until Treasury releases the full licenses, we don't know what those circumstances are.

Additional fields are available if you download the full file.

This is from the first interim response to a FOIA Request filed in May, 2020; see their letter explaining what has been produced here. It took the U.S. Treasury Department roughly 17 months to produce this list, although the request--which sought the text of the license documents, not a spreadsheet of them--is still pending after nearly two years. The letter somewhat inaccurately describes the modifications we've agreed to: our understanding is that OFAC will send the full text of a subset of these licenses once they've been redacted.

It's not clear why Treasury is so slow to process these requests; there is certainly precedent for releasing them. A similar listing of applications for licenses to do business with N. Korea--and the text of the licenses--is available here.

If you're interested in reviewing any of the licenses, please consider FOIA-ing the license from OFAC yourself. If you're able, ask for expedited handling and cite the license number. Also consider that a license active in 2020 may have been superseded by a newer license, or may have subsequently been canceled or modified.

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