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

Date issued: Apr. 19 2024

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TURBOFAC Commentary (1965 words)

Notes

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. 14024 for being owned or controlled by, directly or indirectly, VTB Bank.” One of those subsidiaries was VTB Bank Europe SE (“VTBE”),...