Russia-related General License 92 - Authorizing the Offloading of Cargo from Sovcomflot Vessels (February 23, 2024)

Date issued: Feb. 23 2024

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TURBOFAC Commentary (504 words)

Notes Common to Sovcomflot-related GLs

1) On 2-23-24, OFAC designated Joint Stock Company Sovcomflot (Sovcomflot), a large Russian shipping company. Sovcomflot had previously been subject to the Directive 3 Under EO 14024 "new debt" and "new equity" prohibitions.

In connection with the designation (see https://home.treasury.gov/news/press-releases/jy2121), OFAC added "14 crude oil tankers as property in which Sovcomflot has an interest" to the SDN list.

OFAC also issued GLs authorizing, through April 8, 2024 (i) transactions "ordinarily incident and necessary to the wind down of any transaction involving" Sovcomflot (Russia-related GL 88A, standard wind-down GL), (ii) certain "limited safety and environmental transactions" involving Sovcomflot and its blocked vessels (Russia-related GL 91A), and (iii) transactions "ordinarily incident and necessary...