Russia-related GL 6 (“Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, or the Coronavirus Disease 2019 (COVID-19) Pandemic”) remains valid and authorizes, among other things, transactions ordinarily incident and necessary to (1) the exportation or reexportation of agricultural commodities, including products such as fish, seafood, or preparations thereof — to the extent they fall within the definition of agricultural commodities provided in GL 6 — to, from, or transiting the Russian Federation (see FAQ 979). However, GL 6 does not authorize any transactions prohibited by E.O. of March 11, 2022. As such, U.S. persons can continue to rely on GL 6 for transactions otherwise prohibited by E.O. 14024 involving agricultural commodities, such as fish, seafood, and preparations thereof, provided such transactions are not for the importation of these Russian origin products into the United States, unless otherwise authorized by OFAC.
March 11, 2022