Russia-related General License 37 - Authorizing the Wind Down of Transactions Involving Nord Gold PLC (June 2, 2022)

Date issued: Jun. 02 2022

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TURBOFAC Commentary (331 words)

Notes:

1) Except as described below, 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. FAQ # 990 (no debits to a blocked account on the books of a U.S. financial institution) certainly applies here. This FAQ appears to lend support to the idea that FAQ # 975 (no payments,...