Russia-related General License 54A - Authorizing Certain Transactions Involving VEON Ltd. or VEON Holdings B.V. Prohibited by Executive Order 14071 (January 17, 2023) [PDF includes all versions]

Date issued: Jan. 17 2023

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TURBOFAC Commentary (1333 words)

Notes:

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0) On 1-17-23, OFAC amended FAQ # 1055, which governs the relationship between the "new investment" prohibition and third-country companies, like VEON, that derive significant revenue attributable to Russia. The comments below the asterisks were drafted in connection with the release of "Russia-related General License 54", which was issued when the original version of FAQ # 1055 was still in force. On 1-17-23, OFAC amended this GL to add the "VEON Holdings B.V." in what is now "debt or equity securities of VEON Ltd. or VEON Holdings B.V." The comments below have not been amended in light of the issuance of the amended FAQ # 1055 and Russia-related General License 54A.

With respect to the amendment to the GL, it appears that for the purposes of the prohibition on “purchasing a debt…interest in, entities located outside of the Russian Federation” (new FAQ...