Russia-related General License 69 - Authorizing Certain Debt Securities Servicing Transactions Involving International Investment Bank (May 31, 2023)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (250 words)

Notes:

1) The International Investment Bank (IIB) (https://iib.int/en) is a formerly multilateral development institution. According to Wikipedia:

Initially made it up of all Warsaw Pact members led by the Soviet Union alongside Cuba, Mongolia and Vietnam under the Eastern Bloc during the Cold War, IIB's membership was largely maintained until that point. East Germany withdrew from the IIB in 1990 following German reunification, Poland left in 2000 prior to joining the European Union and the Czech Republic and Slovakia (formerly part of Czechoslovakia) exited the organization following the 2022 Russian invasion of Ukraine with Bulgaria and Romania to follow. In April Hungary announced it was leaving as a result of sanctions on the Hungarian management of the bank.[2] This leaves Russia as the remaining European member of IIB.

https://en.wikipedia.org/wiki/International_Investment_Bank

The IIB was blocked pursuant to 14024 on 04/12/2023. On May 25, 2023, the bank issued a statement that:

"as a result of the imposed US OFAC sanctions, all correspondent banking entities of IIB in the EU blocked all transactions in connection with IIB, including Bank’s nostro accounts in EUR, USD, HUF, CZK, RON.

By the decisions of the correspondent banking entities, IIB is technically unable to make payments under standard payment arrangements and therefore has been deprived of the possibility to fulfil obligations in the abovementioned currencies to bondholders, creditors and clients."

This is clearly designed at rectifying that problem, particularly as it relates to non-Russian creditors of the bank.

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Russia-related General License 69 - Authorizing Certain Debt Securities Servicing Transactions Involving International Investment Bank (May 31, 2023)

TURBOFAC Commentary (250 words)