OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 21A
Authorizing the Wind Down of Sberbank CIB USA, Inc. and Alrosa USA, Inc.
(a) Except as provided in paragraph (b) of this general license, U.S. persons are authorized to engage in all transactions ordinarily incident and necessary to the wind down of Sberbank CIB USA, Inc. or Alrosa USA, Inc. (collectively, the “blocked entities”), or any entity in which the blocked entities own, directly or indirectly, a 50 percent or greater interest, that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including the processing and payment of salaries, severance, and expenses; payments to vendors and landlords; and closing of accounts, through 12:01 a.m. eastern daylight time, June 7, 2022....
1) This wind-down GL is irregular insofar as it covers activities with U.S. persons. For that reason, OFAC clarifies that "the processing and payment of salaries, severance, and expenses; payments to vendors and landlords; and closing of accounts" are "transactions ordinarily incident and necessary to the wind down of Sberbank CIB USA, Inc. or Alrosa USA, Inc." This view is consistent with the view taken in certain specific licenses issued by OFAC for winding down dealings with blocked U.S. persons.
2) This GL was amended on the day after it was initially issued to cover Alrosa USA, Inc., which was blocked on April 7, 2022.
3) Compare Russia-related General License 22 and Russia-related General License 24 which allow for the winding down of transactions involving the non-U.S. parent companies...