OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 112
Authorizing Civil Aviation Safety and Wind Down Transactions Involving Shaurya Aeronautics Private Limited
(a) Except as provided in paragraph (c), all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving Shaurya Aeronautics Private Limited (Shaurya), or any entity in which Shaurya owns, directly or indirectly, a 50 percent or greater interest (collectively, the “Blocked Persons”), are authorized through 12:01 a.m. eastern standard time, December 14, 2024, provided that the goods, technology, or services that are provided, exported, or reexported are for use on aircraft operated solely for civil aviation purposes.
(b) Except as provided in paragraph (c) of this general license, all transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the wind down of any transaction involving the Blocked Persons, are authorized through 12:01 a.m. eastern standard time, December 14, 2024, provided that any payment to the Blocked Persons must be made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).
(c) This general license does not authorize:
(1) Any transactions prohibited by Directive 2 under E.O. 14024, Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions;
(2) Any transactions prohibited by Directive 4 under E.O. 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation; or
(3) Any transactions otherwise prohibited by the RuHSR, including transactions involving any person blocked pursuant to the RuHSR other than Blocked Persons described in paragraphs (a) and (b) of this general license, unless separately authorized.
Note to General License 112. Nothing in this general license relieves any person from compliance with any other Federal laws or requirements of other Federal agencies, including export, reexport, and transfer (in-country) licensing requirements maintained by the Department of Commerce’s Bureau of Industry and Security under the Export Administration Regulations, 15 CFR parts 730–774.
Lisa M. Palluconi
Acting Director
Office of Foreign Assets Control
Dated: October 30, 2024
1) Paragraph (b) is a standard wind-down general license, authorizing the processing of underlying transactions that may not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities. Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this. See in particular Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.
2) Paragraph (a) temporarily authorizes "the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation" irrespective of whether the transactions wouldn't otherwise qualify as a wind down transaction (i.e. "new" contracts are authorized). The scope of paragraph (a) is not elaborated on, but see Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry for an indication of what may be covered. Compare Russia-related GL 40C (very similar), and comments thereto. A substantive difference between this GL and GL 40 is that GL 40 had a condition that the “[t]he aircraft [must be] registered in a jurisdiction solely outside of the Russian Federation.”