Russia-related General License 88A - Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on February 23, 2024 (February 23, 2024)

Date issued: Feb. 23 2024

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (178 words)

Notes:

1) This is a standard wind-down general license, authorizing the processing of underlying transactions even where those underlying transactions do not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities.

2) Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this. See in particular Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.

3) See related debt/equity divestment GL at Russia-related GL 90.

4) NOTE: This GL excludes all transactions prohibited by other EOs of which the prohibitions are incorporated into the Russian Harmful Foreign Activities Sanctions (including the "new investment" prohibition of...