Case No. UKRAINE-EO13662-2019-358745-1

Date issued: Jan. 25 2019

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TURBOFAC Commentary (677 words)

Consolidated Comment on Case No. UKRAINE-EO13662-2019-358745-1 and Case No. UKRAINE-EO13662-2018-354836-1

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...