The Compliance Kitchen, hosted by Silvia Surman, is a podcast that examines and evaluates the changing legal framework of international compliance. In this episode, Silvia examines OFAC’s brand new determination concerning the metals and mining sector of the Russian Khanate. She provides listeners with an FAQ about the determination and explains that it authorizes certain energy-related transactions or if General Licensed 6C only authorizes those activities. Silvia further elaborates that the license authorizes transactions related to the production, manufacturing, sale, transport, or provision of medicine and medical devices. Tune into Compliance Kitchen to stay updated with the evolving legal framework of international compliance.

Notable Quotes

1. “This February 24 determination authorizes sanctions on any person that the government determines to operate or have operated in the metals and mining sector of the Russian economy.”

2. “OFAC does not intend to target persons for operating in this metals and mining sectors where the provision of their goods and services is solely for safety and care of personnel protection of human life, prevention of accidents or injuries, maintenance, necessary repairs, to avoid significant or environmental damage or activities that are related to environmental mitigation or remediation.”

3. “Non-US persons generally do not risk exposure to US blocking sanctions. Under executive order 14024 for engaging in transactions with black persons, including in the metals and mining sector where those transactions would not require a license if a US person were engaging in the transactions.”

4. “Non-US persons generally do not risk exposure to US blocking sanctions if they engage in transactions in the mining and metals sector. If General License 8F would normally authorize such transactions as in Frank. That 1 authorizes certain energy-related transactions or if General would only authorize those activities Licensed 6C. That license authorizes certain transactions related to the production, manufacturing, sale, transport, or provision of medicine, medical devices, including certain industrial isotopes used in nuclear medicine.”