Russia-related General License 28B - Authorizing the Wind Down and Rejection of Certain Transactions Involving Public Joint Stock Company Transkapitalbank and Afghanistan (January 17, 2023) [PDF includes all versions]

Date issued: Jan. 17 2023

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TURBOFAC Commentary (259 words)

Notes:

1) Read in conjunction with Russia-related General License 29, which is a standard wind-down GL for Public Joint Stock Company Transkapitalbank.

2) This GL is/was unique among all Russia-related GLs issued to date, and presumably exists to account for a particular presence of Transkapitalbank in Afghanistan.

3) (Comment regarding Russia-related General License 28A)

Read in conjunction with FAQ # 975 and FAQ # 990. Does FAQ # 990 (no debits to a blocked account on the books of a U.S. financial institution) apply here? What about FAQ # 975 (no payments, at least with respect to loans, unless to a blocked account)? Given that the GL authorizes the operation of "correspondent accounts on behalf of TKB," and "correspondent accounts" are accounts on the books of a U.S....