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LICENSE No. RUSSIA-EO14024-2025-1340848-1
RUSSIAN HARMFUL FOREIGN ACTIVITIES SANCTIONS REGULATIONS
LICENSE
(Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Executive Orders 14024, 14066, 14068, 14071, and 14114 and 31 C.F.R. Parts 501 and 587.)
To: Julian Moroney
c/o [ ]
1200 Seventeenth Street, NW
Washington, DC 20036
Attn: [ ]
1. Based upon the request dated February 14, 2025, and additional correspondence dated February 19, 2025, on behalf of Damien Murran and Julian Moroney, and information otherwise available to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and with all regulations, rulings, orders, and instructions issued under any of...
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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...