Russia-related General License 15 - Authorizing Transactions Involving Certain Blocked Entities Owned by Alisher Burhanovich Usmanov (March 3, 2022)

Date issued: Apr. 12 2023

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TURBOFAC Commentary (200 words)

Notes:

1) Up through its 4-14-23 revocation, this GL was unique among the Russia-related GLs, and uniquely broad. On 4-14-23, OFAC issued Russia GL 62, Russia GL 63, Russia GL 64 and Russia GL 65 to authorize certain dealings with Usmanov-linked entities that were previously authorized by Russia GL 14.

2) For comments on the revocation of this GL and concurrent designations, see Treasury Targets Russian Financial Facilitators and Sanctions Evaders Around the World (Press Release).

**pre-revocation comments follow**

1) Unusual GL that effectively "undoes" what would otherwise be the effect of the 50% rule as it relates to certain entities that are blocked by operation of law due to 50% or greater ownership by Alisher Burhanovich Usmanov. The entities are technically blocked by operation of...