New Sanctions on Russia: What Donors Need to Know
As the U.S. sanctions on Russia are changing, here is what donors need to know to stay regulatory compliant.
Updated on July 14, 2022
CAF America continues to monitor the growing number of U.S. sanctions on Russia. We remain committed to facilitating regulatory-compliant grants to charity partners that follow CAF America’s policies and all relevant U.S. laws and regulations. During this period of rapid change, CAF America is here to help interpret what these new developments mean for our donors and charity partners.
Here is what is relevant for you to understand so far:
- On February 21, 2022, President Biden issued Executive Order 14065, which initiated economic sanctions against Russia and restricts any financial contributions by U.S. individuals and entities into the cities of Donetsk and Luhansk, Ukraine. This adds to the restriction that was already in place in Crimea.
- On February 24, 2022 The U.S Treasury imposed stricter economic sanctions against Russia, targeting state-owned banks and their subsidiaries thus severely limiting U.S. transactions into the country.
- On February 26, 2022 The White House issued a joint statement, along with other world leaders, issuing additional economic restrictions against Russia. These restrictions include selected Russian banks to be removed from the SWIFT messaging system.
- On February 28, 2022 The U.S. Treasury sanctioned key financial institutions and a Russian sovereign wealth fund, preventing Russia from accessing international reserves.
General Licenses for Russia (current 7/14/22)
On July 14, 2022, the US Treasury’s Office of Foreign Assets Control issued three new General Licenses that authorize certain activities in Russia and relating to the firm named SEFE Securing Energy for Europe GmbH (formerly known as Gazprom Germania GmbH). General Licenses are broad-sweeping exemptions to sanctions on activities, individuals or entities that fall under the US sanctions regime. The activities that these licenses allow are narrowly defined:
- Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, COVID-19 Pandemic, or Clinical Trials (GL 6B)
- Transactions Involving SEFE Securing Energy for Europe GmbH (GL 30A)
- Export or Reexport of Certain Accounting Services to U.S. Individuals Located in the Russian Federation (GL 44)
- Transactions Related to Telecommunications and Certain Internet-Based Communications (GL 25C)
Implications for Grantmakers
These licenses make little change to the sanctions environment for grantmaking to Russia. Funders should note that GL 6B merely replaces GL 6A, which was issued in March 2022 and has little substantive difference.
See more info from the OFAC website on the full set of actions here.
Donors intending to support charitable activities supporting the Ukrainian people need to consider that all funders’ ability to work in Russia and specific regions of Ukraine will be very limited, and will be handled on a case by case basis as the military situation and sanctions regimes develop. We will continue to update our process and alerts accordingly to ensure that all legal giving options remain available to you, and that charities that meet our standards can access any available funding.
CAF America is working diligently to highlight additional giving opportunities for donors that includes the option to donate to support refugees, counseling, community centers, international organizations, or other projects in the countries around Ukraine as they are shared with us. CAF America is maintaining a list of all eligible organizations that can verify they are responding to the crisis. Stay tuned for more updates.
If you have previously donated to eligible organizations in Russia and Ukraine the organization(s) may become ineligible to receive funds as CAF America monitors U.S. sanctions. We encourage you to please reach out to email@example.com or your organization’s fund manager for any questions or concerns you may have regarding philanthropic giving to Ukraine or Russia. As the situation develops, our staff will be updated to assist you with any questions you may have.
CAF America is committed to serving our donor clients, especially in the face of conflict. Our main focus remains on protecting your ability to give as donors through our regulations, risk, and reputational model. This includes following all U.S. laws and IRS guidelines and protocols related to charitable giving as political situations unfold around the globe.
About the authors:
Corrine Bonnerwith is CAF America’s Assistant Project Manager. Her responsibilities include working with our internal teams as well as external partners to build out, manage, and facilitate enhancement projects.
Rebekah Siddique is a Validations Associate at CAF America. Her responsibilities include communicating with charity organizations to facilitate the completion of eligibility applications and validation of grantee organizations.