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LICENSE No. MUL-2023-1076594-3
RUSSIAN HARMFUL FOREIGN ACTIVITIES SANCTIONS REGULATIONS UKRAINE-/RUSSIA-RELATED SANCTIONS REGULATIONS
LICENSE AMENDMENT
(Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701 et seq., Executive Orders 13660, 13661, 13662, 13685, 14024, 14039, 14065, 14066, 14068, 14071, and 14114, and 31 C.F.R. Parts 501, 587, and 589.)
To: Bank of Moscow JSC f.k.a. PJSC Bank Otkritie Financial Corporation
c/o Akrivis Law Group, PLLC
5335 Wisconsin Avenue, N.W., Suite 440
Washington, DC 20015 Attn: Farhad Alavi
1. Based upon the request dated May 5, 2023, and additional correspondence dated May 12, 2023, May 16, 2023 May 18, 2023, May 22, 2023, May 24, 2023, May 30, 2023, June 27, 2023, August 3, 2023, August 7, 2023, August 24, 2023, August 28, 2023, August 29, 2023, August 30,...
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1) This license was issued in connection with a state court litigation in which a blocked person was a plaintiff and a non-sanctioned U.S. person with assets in the U.S. was a defendant. The blocked plaintiff moved to have the state court recognize a foreign (Russian) judgment issued in favor of the plaintiff against the defendant. The court (see pp. 27 et seq. of the native PDF) ruled, almost certainly incorrectly, that it was barred not only from enforcing the judgment, but merely from “recognizing” the judgment as valid. The court reasoned that “while recognition is technically distinct from enforcement, recognition here appears to be merely a procedural step towards enforcement,” which is true, but OFAC has long regarded the scope of the blocking prohibition triggering at specified steps, i.e. the point at which a court would be engaged in the “transfer”...