The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has issued two amended general licences under the Ukraine-Related Sanctions Regulations (‘URSR’).
General License No 12A, which was issued in April to allow for the maintenance or winding down of existing contracts or operations with Russian companies hit by US sanctions, such as RUSAL, GAZ Group and EN+ Group, has been replaced by General License No 12B. The new licence has been issued to allow blocked persons access to the funds necessary for authorised wind-down and maintenance activities, and also to allow US financial institutions to handle these funds. The authorisation is valid until 5 June 2018.
General License 13, which authorised US persons to divest or transfer debt, equity or other holdings in companies such as EN+ Group plc, GAZ Group and Rusal until 7 May 2018, has been replaced by General License 13A. The new licence extends the deadline for such divestiture until 6 June 2018. It also covers transactions involving holdings where the sanctioned Russian companies have an indirect or direct ownership of 50% or more.
OFAC has issued FAQs to aid exporters.
General License 12B can be found here:
General License 13A can be found here:
OFAC’s FAQs (three new FAQs at 583-585 and four revised at 570,571,578 and 582) can be found here: