LICENSE No. MUL-2022-900756-8

Date issued: Jul. 30 2024

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TURBOFAC Commentary (222 words)

Notes:

1) This is an unusual license that authorizes transactions "ordinarily incident and necessary to the wind down of" specified blocked entities, rather than (the more typical) transactions ordinarily incident and necessary to the wind down of transactions involving a given blocked entity. See generally Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs.

Here, the blocked entity at issue is Sberbank Europe AG (an SDN at the time the license was issued) and entities blocked pursuant to the 50 Percent Ruled due to ownership by Sberbank Europe AG. The license is notable insofar as it implies that each of the following types of activities are capable of being covered by an authorization for “transactions that are ordinarily incident and necessary to the wind down...