Russia-related General License 10C  - Authorizing Certain Transactions Related to Derivative Contracts (April 7, 2022) [PDF contains all versions]

Date issued: Apr. 07 2022

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TURBOFAC Commentary (256 words)

Notes:

1) Russia-related General License 9 and Russia-related General License 10 authorize different securities-related transactions involving the same entities. Both expire on May 25, 2022.

2) See FAQ # 981, FAQ # 990 and FAQ # 974. Unlike the general wind-down GLs that apply to some of these entities, these two GLs authorize "[d]ebits to accounts on the books of a U.S. financial institution of the blocked entities"..."to the extent ordinarily incident and necessary to effect the transactions authorized".

3) Query: what if any transactions involving Sberbank are authorized by this GL that would otherwise be prohibited by the sanctions applicable to Sberbank as of the date of the issuance of the GL? Potential answer: trades involving Sberbank debt or equity, including derivatives thereof, may be within the...