Russia-related General License 85 - Authorizing the Wind Down of Transactions and the Closure of Accounts Involving Expobank Joint Stock Company (December 22, 2023)

Date issued: Dec. 22 2023

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TURBOFAC Commentary (150 words)

Notes:

1) Paragraph (a) of the GL is a modern standard wind down GL. Refer generally to Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs, for comments on the scope of the typical wind down GL.

2) Paragraph (b) is a unique GL allowing the closure of accounts by “persons” with accounts at the bank. Compare Russia-related General License 50, which has no expiration date and allows “all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to…the closing of an account of an individual, wherever located, who is not a blocked person (“the account holder”), held at a financial institution blocked pursuant to E.O. 14024”. Paragraph (b) covers accounts of “person,” where “person” includes “individuals” and “entities,” so...