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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 100A
Authorizing Certain Transactions Related to Debt or Equity or the Conversion of Currencies Involving MOEX, NCC, or NSD
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the divestment of debt or equity to a non-U.S. person, who is not a person whose property or interests in property are blocked, or the conversion of currencies, involving one or more of the following blocked entities that is acting solely as a securities, trade, or settlement depository, central counterparty or clearing house, or public trading market, are authorized through 12:01 a.m. eastern daylight time, October 12, 2024:
(1) Moscow Exchange (MOEX);...
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* 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...