Russia-related General License 55C - Authorizing Certain Services Related to Sakhalin-2 (November 21, 2024)

Date issued: Nov. 21 2024

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TURBOFAC Commentary (219 words)

Notes:

1) Query: To what degree does the GL apply where seaborne Russian oil is destined for Japan, but in a context where it is expected to be re-exported without first being substantially transformed?

2) For comments on the Price Cap Prohibition in general, see Consolidated Comment on the Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil of Russian Federation Origin (the Price Cap).

3) GL amended on 9-14-23 and 6-26-24 to extend the expiration date.

4) On 11-21-24, OFAC blocked JSC Gazprombank, a large Russian financial institution that had previously only been subject to non-blocking directives issued under EO 14024 and EO 13662. Concurrent with the blocking action, OFAC issued this amended GL to add an authorization for...