Russia-related General License 62 - Authorizing the Wind Down of Transactions Involving Holdingovaya Kompaniya Metalloinvest AO, MegaFon PAO, Limited Liability Company USM Telecom, or Akkermann Cement Ca Limited Liability Company (April 12, 2023)

Date issued: Apr. 12 2023

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TURBOFAC Commentary (460 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.

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, at least with respect...