LICENSE No. MUL-2025-1394826-3

Date issued: Jan. 22 2026

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TURBOFAC Commentary (126 words)

Notes:

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”.