Russia-related General License 117 - Authorizing the Wind Down of Transactions Involving Gazprom Neft, Surgutneftegas, and Certain Additional Entities Blocked on January 10, 2025 (January 10, 2025)

Date issued: Jan. 10 2025

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TURBOFAC Commentary (125 words)

Notes:

1) This is a standard wind-down general license covering multiple blocked entities, authorizing the processing of underlying transactions even where those underlying transactions do not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities. Compare Russia-related GL 88.

2) 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.

3) Russia-related General License 117 (general wind down) and Russia-related General License 118 (securities) were issued concurrently and apply to many of the same entities.