Case No. UKRAINE-EO13662-2018-355180-1

Date issued: Sep. 18 2018

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TURBOFAC Commentary (251 words)

Notes:

1) This guidance letter was issued at a time when Rusal America Corporation (a U.S. person) was blocked by operation of law, and Ukraine GL 14 authorized “all transactions and activities…that are ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements, including the importation of goods, services, or technology into the United States, involving United Company RUSAL PLC or any other entity in which United Company RUSAL PLC owns, directly or indirectly, a 50 percent or greater interest and that were in effect prior to April 6, 2018…”

2) In this letter, OFAC provides detailed guidance concerning the scope of the term “maintenance”. For the most part, the guidance replicates the substance of a variety of FAQs issued nearly contemporaneously, in particular FAQ # 625 and FAQ...