Russia-related General License 116 - Authorizing Transactions Involving Entities Owned by Bidzina Ivanishvili (December 27, 2024)

Date issued: Dec. 27 2024

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TURBOFAC Commentary (180 words)

Notes:

1) Read in conjunction with FAQ # 1204, and compare Global Magnitsky General License 8 (similar GL authorizing transactions involving non-designated entities owned by an individual SDN that would otherwise be blocked by the 50 Percent Rule).

2) For information on the litigation carved out of the GL, see https://www.elitigation.sg/gd/s/2024_SGCAI_5. The litigation involves the “Mandalay Trust” which was established “for the benefit of Mr. Ivanishvili and his family” and “comprised bankable assets and various artworks.” Given that the litigation-related provision is a carveout, rather than a “note,” the implication should be that the trust itself is a blocked entity with respect to which dealings could have otherwise been authorized but for the carveout, but it is not necessarily the case that OFAC made an...