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 (520 words)

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

* Refer generally to General Note on the Implications of OFAC’s Blocking of the Russian National Settlement Depository (NSD) (System Ed. Note).

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...