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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 80
Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Highland Gold Mining Limited
(a) Except as provided in paragraphs (d) and (e) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity of Highland Gold Mining Limited (Highland Gold), or any entity in which Highland Gold owns, directly or indirectly, a 50 percent or greater interest, purchased prior to December 12, 2023 (“Covered Debt or Equity”), to a non-U.S. person are authorized through 12:01 a.m. eastern daylight time, March 11, 2024.
(b) Except...
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1) This is standard "debt/equity" GL, as issued in the Russian context (compare e.g. Russia GL 43 and Russia GL 48), that does not license against Directive 4 Under EO 14024. Refer generally to General Note on GLs and Other Types of Authorizations as Applied to Dealings in or Related to Securities of Sanctioned Issuers, for comments on the scope of the typical wind down GL containing language similar to this one.
2) Read in conjunction with Russia-related GL 79 (Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on December 12, 2023).