Case No. UKRAINE-EO13662-2014-312289-1

Date issued: Nov. 14 2018

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TURBOFAC Commentary (658 words)

Notes:

1) EXIAR is Russia’s state-owned export credit agency, which, as described in the letter, provides “credit insurance…that protects against the non-payment of a loan”. In the case described in the letter, ILS would sell goods or launch services to a non-sanctioned “satellite launch customer [who] obtains a bank loan or financing for the launch and credit insurance from EXIAR to insure the bank loan.” The letter goes on to state that “in a typical transaction involving satellite launch services, the satellite launch customer obtains a bank loan or financing for the launch and credit insurance from EXIAR to insure the bank loan” (which in this case would be “a loan of more than 90 days between a non-sanctioned purchaser of goods or services for launch services contracts and a non-sanctioned bank”). The way export credit insurance works in such circumstances is that, in the event that...