Russia-related General License 100A - Authorizing Certain Transactions Related to Debt or Equity or the Conversion of Currencies Involving MOEX, NCC, or NSD (August 02, 2024)

Date issued: Aug. 02 2024

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TURBOFAC Commentary (499 words)

Consolidated Comment on Russia-related General License 99 and Russia-related General License 100

1) Russia GL 99 and Russia GL 100 cover otherwise prohibited transactions involving three “financial in structure”-related entities.

2) Russia GL 99 is similar to other recent “Debt or Equity of, or Derivative Contracts Involving” GLs (compare e.g. Russia GL 90), with a few notable distinctions. This GL has a “divestment or transfer” authorization (paragraph (b)) which mirrors the authorization of paragraph (a) of Russia GL 90. GL 99 also contains an authorization for “all transactions…that are ordinarily incident and necessary to facilitating, clearing, and settling trades of [debt or equity issued or guaranteed by any of the blocked entities] that were placed prior to…June 12, 2024” and an authorization for “all transactions…that are ordinarily incident and necessary to the wind down of derivative contracts...