Russia-related General License 43A - Divestment or Transfer of Debt or Equity of, and Wind Down of Derivative Contracts Involving, Public Joint Stock Company Severstal or Nord Gold PLC (August 2, 2022) [PDF includes all versions]

Date issued: Aug. 02 2022

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TURBOFAC Commentary (416 words)

Notes:

1) Compare Russia-related General License 9 and Russia-related General License 10 (comments thereto, and related FAQs). This GL serves as a break with OFAC's practice of updating GL 9 and 10 to account for new blocked entities with respect to which OFAC wants to license certain securities-related trades.

2) Compare the following carveouts to GLs 9 and 43:

GL 9: "U.S. persons to purchase or invest in, or to facilitate the purchase of or investment by U.S. persons in, directly or indirectly, covered debt or equity, other than purchases of or investments in covered debt or equity that are ordinarily incident and necessary to the divestment or transfer of covered debt or equity as described in paragraph (a) of this general license."

GL 43: "U.S. persons to...