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LICENSE No. MUL-2022-900756-8
RUSSIAN HARMFUL FOREIGN ACTIVITIES SANCTIONS REGULATIONS
UKRAINE-/RUSSIA-RELATED SANCTIONS REGULATIONS
LICENSE RENEWAL
(Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, Executive Orders 13660, 13661, 13662, 13685, 13849, 13883, 14024, 14039, 14065, 14066, 14068, 14071, 14114, and 31 C.F.R. Parts 501, 587, and 589.)
To: MeSoFa Vermögensverwaltungs AG in Abwicklung, formely Sberbank Europe AG
Kroißberggasse 13
Vienna, Austria 1230
Attn: Pavel Barchugov
1. Based upon the request dated April 8, 2022, and additional correspondence dated May 18, 2022, May 27, 2022, October 18, 2022, October 25, 2022, October 26, 2022, November 21, 2022, November 22, 2022, December 8, 2022, December 9, 2022, December 15, 2022, December 21, 2022, August 16, 2023, August 17, 2023, August 18, 2023, August 22, 2023, September...
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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...