General Note on GLs and Other Types of Authorizations as Applied to Dealings in or Related to Securities of Sanctioned Issuers

Last substantive commentary amendment:
Mar. 11 2024

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TURBOFAC Commentary (3846 words)

General Note on GLs and Other Types of Authorizations as Applied to Dealings in or Related to Securities of Sanctioned Issuers

(I) Background

(a) "All Transactions" (With Provisos)
(b) "Divest or Transfer"
(c) "Wind Down of Derivative Contracts"
(d) "Financial Contracts or Other Agreements"

(II) The Scopes of the Various Types of GLs
(a) The Standard Wind Down GL (No Mention of Securities)
(b) "All Transactions" (With Provisos)
(c) "Divest or Transfer"
(d) "Wind Down of Financial Contracts or Other Agreements"
(e) "Wind Down of Derivative Contracts"
(f) Confusion on the Status of Short Covering
(g) The Meaning of the Standard "to Purchase or Invest in" Exclusion

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*General Note on GLs and Other Types of Authorizations as Applied to Dealings in or Related to Securities of Sanctioned Issuers

(I) Background

There are...