Russia-related General License 102 - Authorizing Certain Transactions Involving VPower Finance Security (Hong Kong) Limited. (August 12, 2024)

Date issued: Aug. 12 2024

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TURBOFAC Commentary (97 words)

Notes:

1) The SDN at issue here (VPOWER FINANCE SECURITY HONG KONG LIMITED) was designated on June 12, 2024, and provides various storage, transport and security services for cash and metals, in addition to other services such as ATM maintenance (see https://v-power.com/). This GL is unusual insofar as it authorizes, on a temporary basis, a certain range of activities with a blocked person outside of the wind-down context. Two notable limitations to the GL are that it only authorizes transactions “within Hong Kong” and it does not apply to transactions involving subsidiaries of VPower.