Treasury Issues New General License On "Wind-Down" Transactions With Sanctioned Russian Companies

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The U.S. Treasury Department Office of Foreign Assets Control ("OFAC") issued a new General License extending the period during which U.S. persons are authorized to engage in certain "maintenance and wind-down"...
United States International Law

The U.S. Treasury Department Office of Foreign Assets Control ("OFAC") issued a new General License extending the period during which U.S. persons are authorized to engage in certain "maintenance and wind-down" transactions and activities with two companies previously sanctioned for reportedly "advancing Russia's malign activities."

The two companies, EN+ Group PLC and JSC EuroSibEnergo, were added to the Specially Designated Nationals and Blocked Persons List on April 6, 2018. General License 12 (as amended by General License 12C) provided that U.S. persons could engage in transactions with specified entities, including EN+ Group PLC and JSC EuroSibEnergo, as they relate to operations, contracts or other agreements that were in place prior to the issuance of the General License until June 5, 2018. The authorization also applies to entities in which any of the named companies holds a 50% or greater interest.

Under newly issued General License 16, the period for wind-down or maintenance transactions and activities related to EN+ Group PLC and JSC EuroSibEnergo was extended until October 23, 2018.

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