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Case No. UKRAINE-EO13662-2018-354836-1
Ambassador Daniel Mulhall
Embassy of Ireland
2234 Massachusetts Avenue, N.W.
Washington, D.C. 20008
Dear Ambassador Mulhall:
This responds to your request dated July 5, 2018 (the “Application”) to the Office of Foreign Assets Control (OFAC) and additional correspondence dated July 2, 2018, seeking relief from Russia-related sanctions as they relate to Aughinish Alumina (AA) in Ireland, which you indicate is owned by United Company Rusal PLC (“Rusal”), an entity designated on April 6, 2018 under the Ukraine-Related Sanctions Regulations, 31 C.F.R. Part 589 (URSR). Specifically, you seek to scope the conditions under which a license specific to AA’s activities and commercial relationships may be granted.
The URSR prohibit all transactions prohibited pursuant to Executive Order 13660 of March 6, 2014 (E.O. 13660), Executive Order 13661 of March 16, 2014 (E.O. 13661), and Executive...
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Like Case No. Ukraine-EO13662-2018-354754-1, this is a request for guidance from the embassy of a country that hosts/hosted a subsidiary of United Company Rusal PLC, which was blocked at the time of the relevant guidance.
In Case No. UKRAINE-EO13662-2018-354836-1 (the first letter issued on 8/17/2018), OFAC issues guidance interpreting Rusal-related Ukraine General License Number 14 (April 23, 2018) (“maintenance or wind down of operations, contracts, or other agreements, including the importation of goods, services, or technology into the United States, involving United Company RUSAL PLC”) in a way that broadly tracks FAQ # 625 (issued after the guidance letter). In Case No. UKRAINE-EO13662-2019-358745-1, the same Irish Ambassador writes to OFAC at a time when Ukraine General License Number 14E was in...