Russia-related General License 113 - Authorizing the Wind Down of Transactions Involving Certain Financial Institutions Blocked on November 21, 2024 (November 21, 2024)

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TURBOFAC Commentary (197 words)

Notes:

1) Compare Russia-related General License 60. This is typical of the now-standard GLs for the wind down of transactions with blocked Russian financial institutions, but note that this version does not authorize any transactions prohibited by Directive 4 Under 14024, whereas other similar GLs do cover certain transactions prohibited by Directive 4, and that this GL does not authorize the rejection of transactions that don’t otherwise qualify for the GL.

2) See related debt/equity divestment GL at Russia-related GL 114.

3) Refer generally to Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs, for comments on the scope of the GL of this variety.

4) By licensing against the entirety of EO 14024 without a carveout for Directive 3 Under EO 14024, this GL appears to implicitly license against Directive 3 Under EO 14024 (debt/equity) to which Gazprombank has been subject since 2-24-22. Is it a mistake/oversight that this GL authorizes transactions that implicated Directive 3 Under EO 14024 that were prohibited prior to the 11-21-24 blocking action? We would imagine so.

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Russia-related General License 113 - Authorizing the Wind Down of Transactions Involving Certain Financial Institutions Blocked on November 21, 2024 (November 21, 2024)

TURBOFAC Commentary (197 words)