Russia-related General License 119 - Authorizing Certain Transactions Involving Public Joint Stock Company Gazprom Neft Related to Diplomatic and Consular Mission Operations Outside of the Russian Federation (January 10, 2025)

Date issued: Jan. 10 2025

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TURBOFAC Commentary (143 words)

Notes

1) Compare Russia-related GL 53A (Authorizing Transactions for Diplomatic Missions of the Russian Federation Involving Gazprombank Joint Stock Company or Prohibited by Directive 4 under Executive Order 14024). While that GL (which is not time limited) makes a degree of sense insofar as Russia may use Gazprombank to process payments by its diplomatic or consular missions outside of Russia and the USG does not want to interfere with that, it is less clear what “diplomatic or consular missions located outside of the Russian Federation” require the time-limited GL for transactions involving Gazprom Neft. Of note, note that this GL (which expires on the same day as the standard wind down GL (Russia-related General License 117) that applies to Gazprom Neft) does not have the “provided that any payment to a blocked person is made into...