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DEPARTMENT OF THE TREASURY
WASHINGTON. D.C.
LICENSE No. MUL-2025-1394826-3
RUSSIAN HARMFUL FOREIGN ACTIVITIES SANCTIONS REGULATIONS
UKRAINE-/RUSSIA-RELATED SANCTIONS REGULATIONS
LICENSE AMENDMENT
(Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701 et seq, Executive Orders 13660, 13661, 13662, 13685, 14024, 14039, 14066, 14068, 14071, and 14114, and 31 C.F.R. Parts 501, 587, and 589)
1. Based upon the request dated and [...] information otherwise available to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized. This License supersedes License No. MUL-2025-1394826-2 in all respects.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under any of the authorities cited above.
3....
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1) Among specific licenses in the Research System or otherwise available for public consumption, this license is one of a kind in terms of its breadth and its implications for OFAC’s licensing policy. The license was issued to an unnamed recipient allowing all “U.S. persons” (some named but redacted but also all other unnamed U.S. persons) to engage in transactions “ordinarily incident and necessary to divest securities” to a redacted buyer, with no limitations on the nature of the issuers or other reasons why the securities are blocked (e.g. NSD or MOEX interest), except that it does not cover securities that are actually “owned” by sanctioned persons.
2) Note the “REPO Act” condition, and the carveout for direct or indirect payments of an “exit tax”.