Russia-related General License 114 - Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on November 21, 2024 (November 21, 2024)

Date issued: Nov. 21 2024

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TURBOFAC Commentary (361 words)

Notes:

1) Except as described below, this is standard "debt/equity" GL, as issued in the Russian context (compare e.g. Russia GL 43 and Russia GL 48), that does not license against Directive 4 Under EO 14024. Refer generally to General Note on GLs and Other Types of Authorizations as Applied to Dealings in or Related to Securities of Sanctioned Issuers, for comments on the scope of the typical wind down GL containing language similar to this one.

2) This is the third ever GL of this type that explicitly authorizes dealings in debt "guaranteed" by specified blocked parties. The implication is that any debt instrument guaranteed is debt in which a blocked person has an interest, such that OFAC authorization is required to deal in such debt....