Russia-related General License 90 - Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on February 23, 2024 (February 23, 2024)

Date issued: Feb. 23 2024

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TURBOFAC Commentary (200 words)

Notes:

1) Except as described below, 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 related wind down GLs at Russia-related GL 88 and Russia-related GL 89.

3) This is the first ever GL of this type that explicitly authorizes dealings in debt "guaranteed" by specified blocked parties. The implication is that...