GL-38A
ActiveAuthorizing Transactions Related to Pension Payments
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Summary
General License No. 38A authorizes all transactions ordinarily incident and necessary to the processing of pension payments to U.S. persons or non-U.S. persons not located in the Russian Federation, where those transactions are prohibited by E.O. 14024. The authorization applies only where the sole involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to E.O. 14024. This license replaces and supersedes General License No. 38, dated June 2, 2022, effective August 19, 2022.
Authorized activities
- Transactions ordinarily incident and necessary to the processing of pension payments to U.S. persons
- Transactions ordinarily incident and necessary to the processing of pension payments to non-U.S. persons not located in the Russian Federation
Conditions
The license does not authorize: (1) opening or maintaining a correspondent account or payable-through account for any entity subject to Directive 2 prohibitions; (2) any debit to an account on the books of a U.S. financial institution 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; (3) any transactions otherwise prohibited by the RuHSR, including transactions involving any blocked person other than those described in paragraph (a), unless separately authorized. The only permitted involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to E.O. 14024.