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1012. Do I have to wind down energy-related transactions by the expiration date of Russia-related General License (GL) 8L?
On January 10, 2025, the Office of Foreign Assets Control (OFAC) amended GL 8L to authorize the wind-down of energy-related transactions through 12:01 a.m. eastern daylight time, March 12, 2025. OFAC issued GL 115A to authorize transactions related to civil nuclear energy involving certain sanctioned Russian financial institutions, including those listed in GL 8L.
Updated: January 10, 2025
Updated on Jan 10, 2025
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1,012. Do I have to wind down energy-related transactions by the expiration date of Russia-related General License (GL) 8A?
GL 8A authorizes energy-related transactions through 12:01 a.m. eastern daylight time, June 24, 2022, unless renewed. In the event that GL 8A is not renewed, OFAC intends to issue a general license authorizing the orderly wind down of activities covered...
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1) Russia-related General License 8 is unusual in that it has a relatively short expiration window, but is not characterized as either a "wind down" or a "maintenance" GL. Here, OFAC signals that GL 8 is effectively a wind down and/or maintenance GL. See generally Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs.
2) FAQ amended on 6-14-22 to reference Russia-related General License 8C / make technical corrections.
3) FAQ amended on 1-10-25 to add references to new and/or updated GLs.