Russia-related General License 94 - Authorizing Transactions Involving OWH SE i.L. (Formerly Known as VTB Bank Europe SE)

Date issued: Apr. 19 2024

Last substantive commentary amendment:
Sep. 14 2026

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TURBOFAC Commentary (1904 words)

Notes

[9-15-26 – Update – GL useless in light of the designation of VTB under EO 13902]

The issuance of this GL and the surrounding circumstances are highly unusual, and illustrate an overlooked feature of the 50% Rule. Skip to section 4, below, for comments on the scope and operation of the GL.

1) BACKGROUND

On 2-24-24, “VTB Bank was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the [Government of Russia], and for operating or having operated in the financial services sector of the Russian Federation economy” and “[i]n addition, 20 VTB Bank subsidiaries were designated [i.e. added to the SDN list] pursuant to E.O....