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Executive Order 13902 of January 10, 2020
(“Imposing Sanctions With Respect to Additional Sectors of Iran”)
GENERAL LICENSE AA
Authorizing Certain Activities Involving La Nivernaise De Raffinage SAS
(a) Except as provided in paragraph (b) of this general license, all transactions prohibited by Executive Order (E.O.) 13902 that are ordinarily incident and necessary to the wind down of any transaction, or the maintenance of operations, contracts, or other agreements in effect as of August 24, 2026, involving La Nivernaise De Raffinage SAS (“LNR”), or any entity in which LNR owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, October 23, 2026.
(b) This general license does not authorize any transactions otherwise prohibited by E.O. 13902, including transactions involving any person blocked pursuant to E.O. 13902 other...
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1) This is a standard wind-down general license, authorizing the processing of underlying transactions that may not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities.
2) With respect to the scope of the typical "wind-down" GL, consult the relevant portions of Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.
3) Note that the entity at issue here is a French entity blocked due to ownership by a different SDN, such that the warning that the “general license does not authorize any transactions otherwise prohibited by E.O. 13902, including transactions involving any person blocked pursuant to E.O. 13902 other than the blocked persons described in...