LICENSE No. RUSSIA-EO14024-2025-1340848-1

Date issued: Feb. 20 2025

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TURBOFAC Commentary (1253 words)

Notes:


1) BACKGROUND - Public Joint Stock Company State Transport Leasing Company (GTLK) was first added to the SDN List (pursuant to EO 14024) on August 2, 2022 (https://home.treasury.gov/news/press-releases/jy0905). GTLK was designated pursuant to EO 13662 on January 15, 2025 (https://ofac.treasury.gov/recent-actions/20250115). GTLK has two Irish subsidiaries that appear on the SDN List (GTLK Europe DAC and GTLK Europe Capital DAC). Those GLTK entities are “subject to liquidation proceedings in Ireland…to a winding up order dated 31 May 2023” (p. 3, PDF). GTLK Europe DAC has/has two subsidiaries, “STLC 5” and “STLC 25,” that are Irish entities (p. 81, PDF), neither of which were subject to liquidation proceedings as of the time of the license (p. 164, PDF). “GLTK Capital provided funding to STLC 25 to acquire three aircraft, two of...