Russia-related General License 65 - Authorizing Transactions Related to Telecommunications and Certain Internet based Communications Involving MegaFon PAO or Digital Invest Limited Liability Company (April 12, 2023)

Date issued: Apr. 12 2023

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TURBOFAC Commentary (298 words)

Notes:

1) Up through 4-12-2023, the entities at issue here were blocked by operation of law as a result of their being indirectly owned by the SDN Alisher Burhanovich Usmanov (Usmanov), but transactions involving such entities 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) OFAC explains the purpose of this GL, and its relationship to Russia-related General License 25C, in FAQ # 1122. Russia-related General License 25C authorizes telecommunications transactions...