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1,008. Is there a wind-down period for the prohibitions imposed in Executive Order (E.O.) 14065?
Yes. Through 12:01 a.m. eastern daylight time on March 23, 2022, Ukraine-related General License 17 authorizes transactions that are ordinarily incident and necessary to the wind down of transactions involving the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine. Given the comprehensive nature of the sanctions on these regions, these activities include the divestiture or transfer to a non-U.S. person of a U.S. person’s share of ownership in any pre-February 21, 2022 investment located in the DNR or LNR regions of Ukraine, and the winding down of operations, contracts, or other agreements in effect prior to February 21, 2022 involving the exportation, reexportation, sale, or supply of goods, services, or technology to, or importation of any goods, services, or technology from, the DNR or LNR regions of...
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1) Refer to Ukraine General License Number 17. The FAQ does not appear to breach much new ground on the scope of an otherwise standard "wind down" GL, but note the clarification concerning "divestments". Divesting to a U.S. person is presumably not authorized because that would be facilitating the U.S. person's otherwise prohibited "new investment" in the embargoed areas. Compare 586.409 Approval or other facilitation of other persons' investment in the territory of the Republic of Serbia.