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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 123
Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Wafangdian Bearing Company Limited
(a) Except as provided in paragraphs (d) and (e) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by Wafangdian Bearing Company Limited (Wafangdian), or any entity in which Wafangdian owns, directly or indirectly, a 50 percent or greater interest, (“Covered Debt or Equity”) to a non-U.S. person are authorized through 12:01 a.m. eastern standard time, March 1, 2025.
(b) Except as provided in paragraph (e) of this general license,...
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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 a rare GL 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. Compare