Russia-related General License 32 -  Authorizing the Wind Down of Transactions Involving Amsterdam Trade Bank NV (May 5, 2022)

Date issued: May. 05 2022

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TURBOFAC Commentary (201 words)

Notes:

1) This is a standard wind-down general license, authorizing the processing of underlying transactions that may not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities.

2) Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this. See in particular Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.

3) Read in conjunction with FAQ # 975 and FAQ # 990, which appear to impose significant restrictions on this GL that are not otherwise clear from the face of the GL. FAQ # 990 (no debits to a blocked account on the books of a U.S....