Russia-related General License 4 ,"Authorizing the Wind Down of Transactions Involving Nord Stream 2 AG".

Date issued: Feb. 23 2022

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TURBOFAC Commentary (681 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. See relevant related items at Secondary Sanctions Enforcement Announcement - Sanctioning NS2AG, Matthias Warnig, and NS2AG’s Corporate Officers (State Dep't); Statement by President Biden on Nord Stream 2 (Feb. 23, 2022).

3) 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.

4) Query: does this GL authorize the dealings in property that was in the "possession or control" of U.S. persons at the time...