General License 30 - Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on October 7, 2024 (October 7, 2024)

Date issued: Oct. 07 2024

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TURBOFAC Commentary (194 words)

Notes:

1) Compare e.g. Global Magnitsky General License 5, another standard GL for “Transactions Related to Debt or Equity of, or Derivative Contracts”. Refer generally to General Note on GLs and Other Types of Authorizations as Applied to Dealings in or Related to Securities of Sanctioned Issuers for comments on the scope and operation of GLs such as these, but note the distinction between this GL and (e.g.) Russia-related GL 90 and Russia-related GL 99. Certain Russia-related GLs with “Transactions Related to Debt or Equity of, or Derivative Contracts Involving” in the title cover “debt or equity issued or guaranteed by” specified blocked persons, but this GL omits the “guaranteed by”. It is not clear whether this omission is intentional, such that debt “guaranteed by” the relevant blocked persons are not covered, or...