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OFAC FAQ (Current) # 1103 - Russian Harmful Foreign Activities Sanctions

Date issued: Dec. 15 2022

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1103. Is there a wind-down period for transactions involving Public Joint Stock Company Rosbank (Rosbank), which was blocked on December 15, 2022 pursuant to Executive Order (E.O.) 14024? What transactions are authorized during the wind-down period?

OFAC issued General Licenses (GL) 58 and 59 concurrent with the designation of Rosbank. GL 58 authorizes a wind-down period for transactions involving Rosbank or any entity in which Rosbank owns, directly or indirectly, a 50 percent or greater interest (“Rosbank entities”) until 12:01 a.m. eastern daylight time, March 15, 2023. This includes transactions ordinarily incident and necessary to exit operations, contracts, or other agreements involving Rosbank entities that were in effect prior to December 15, 2022, provided that such transactions do not involve a debit to a blocked account on the books of a U.S. financial institution (see Frequently Asked Question (FAQ) 990). Wind-down activities covered by GL 58 do...

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TURBOFAC Commentary (349 words)

Notes:

1) Compare FAQ # 975, which also addressed the scope of wind down GLs applicable to blocked financial institutions and on which this FAQ is modeled, and read in conjunction with Russia GL 58 and Russia GL 59.

2) Refer generally to Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs, for comments on the scope of the typical wind down GL containing language similar to Russia-related GL 58 and Russia-related GL 59.

3) The following sentence is extremely confusing:

Wind-down activities covered by GL 58 do not include the continued processing of funds transfers, securities trades, or other transactions that involve a Rosbank entity that were part of ongoing business activities prior to the imposition of sanctions, unless separately authorized (see,...