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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 117
Authorizing the Wind Down of Transactions Involving Gazprom Neft, Surgutneftegas, and Certain Additional Entities Blocked on January 10, 2025
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the blocked entities listed in the Annex to this general license, or any entity in which those blocked entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern standard time, February 27, 2025, provided that any payment to a blocked person is made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31...
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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.