As the world turns… There have been several key developments recently in the Russia sanctions context:
- Issuance of General License 15. This general license, issued May 22, authorizes maintenance and winding down of pre-April 6 business with GAZ Group and its subsidiaries through October 23. The authorization is similar in scope to General License 14, issued on April 23 with respect to Rusal.
- Issuance of General License 13B. This general license, issued May 31, added EN+ Group PLC to the list of companies (previously consisting of GAZ Group and Rusal) for which divestment of holdings is permitted, and extended the deadline for divestment from June 6 to August 5. The general license also permits divestment of holdings in the subsidiaries of the covered companies under certain circumstances.
- Issuance of General License 16. This general license, issued just yesterday, authorizes certain activities to maintain or wind down pre-April 6 business with EN+ Group PLC, EuroSibEnergo, and their subsidiaries through October 23.
- Lapse of General License 12C. This general license previously had authorized certain activities to maintain or wind down pre-April 6 business with several Russian companies (see the list below). That authorization lapsed yesterday, meaning that business with the companies covered by the general license no longer is permitted.
- President Putin signs Russian “counter-sanctions” into law. Yesterday, President Putin signed into law a bill that gives him the power to sever relations with “unfriendly” countries and prohibit trade with such countries. Notably, the bill as initially proposed would have banned a range of US goods and services, including certain US food, alcohol, medicine, and consulting services, but it was watered down significantly before reaching the president’s desk. Consideration of a related bill, which would criminalize compliance with US sanctions on Russian soil, has been postponed for the time being.
So where do things stand? Here’s a short summary:
Continue Reading Russia Sanctions: General Licenses, Deadlines, Russian Counter-Measures– What’s the Latest?