ARTICLE
29 May 2018

Treasury Issues New And Revised Ukraine-/Russia-Related General Licenses

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Cadwalader, Wickersham & Taft LLP

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The U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") issued one new and replaced one existing General License concerning Russia-related entities ...
United States International Law

The U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") issued one new and replaced one existing General License concerning Russia-related entities on the Specially Designated Nationals and Blocked Persons list ("SDN list"). These General Licenses are among a series of revisions to Ukraine-/Russia-related sanctions by OFAC to mitigate potential disruptions to international markets.

General License 15 allows U.S. persons to engage in maintenance or wind-down transactions and activities with the GAZ Group and its subsidiaries until 12:01 a.m., Eastern Daylight Time, on October 23, 2018. This represents an extension of nearly five months compared to the previous deadline of June 5 for authorized maintenance and wind-down transactions related to GAZ Group. (A similar extension was previously granted for authorized transactions related to RUSAL PLC.) In addition, General License 12C was issued to replace General License 12B in order to make conforming edits reflecting the authorizations contained in General License 15.

To provide additional guidance, OFAC published six new FAQs and updated several previous FAQs.

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