Yesterday, OFAC issued General License No. 15 under the Ukraine-Related Sanctions Regulations (31 C.F.R. Part 589), authorizing the maintenance or wind-down of pre-April 6 contracts with GAZ Group and its subsidiaries through October 23, 2018. Previously, such activity with GAZ Group was permitted only through June 5, 2018 as per General License No. 12B (which has since been superseded, as described below). OFAC also issued six new Frequently Asked Questions (FAQs).
Similar to the recent easing of restrictions against Rusal as set out in General License No. 14, the new general license extends the period of authorized maintenance/wind-down-related dealings with GAZ Group through October 23, permits exports from the United States to GAZ Group in support of such activity, and removes the requirement that payments to GAZ Group for maintenance/wind-down purposes be made into a blocked account in the United States. The general license does not authorize divestiture of debt or equity (which is covered by General License No. 13A), dealings with other sanctioned entities (unless permitted by General License No. 12C, described below), or the unblocking of property except for use in maintenance/wind-down-related activity.
As with the general license for Rusal, while the authorization is directly applicable for U.S. persons, it is also of significance to non-U.S. persons. Continue Reading