Russia-related General License 64 - Authorizing Certain Transactions Involving Kommersant (April 12, 2023)

Date issued: Apr. 12 2023

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TURBOFAC Commentary (489 words)

Notes:

1) Up through 4-12-2023, Joint-Stock Company Kommersant was blocked by operation of law as a result of it being indirectly owned by the SDN Alisher Burhanovich Usmanov (Usmanov) (https://en.wikipedia.org/wiki/Kommersant), but transactions involving Kommersant were broadly authorized by Russia-related General License 15. On 4-12-2023, OFAC revoked Russia-related General License 15. As is the case with Russia-related General License 15, transactions covered by this GL cannot involve Usmanov himself, because there is a carveout for "transactions involving any person blocked pursuant to the RuHSR other than the blocked persons described in paragraph (a) of [the] general license".

2) This GL is unique among all active OFAC GLs. The term "operations of" is not a defined term of art. This is probably narrower than Russia-related...