OFAC FAQ (Current) # 569 - Ukraine-/Russia-related Sanctions

Date issued: Apr. 23 2018

TURBOFAC Commentary (104 words)

Notes:

1) Ukraine GL 12A has been amended and replaced by Ukraine GL 12B, which in turn was replaced by Ukraine GL 12C, all of which have expired.

2) Note that the scope of the companies included in the GL covers some that remain blocked subsequent to OFAC's delisting of Rusal, and some that remain blocked.[1]

[1] https://home.treasury.gov/news/press-releases/sm592

3) Guidance provided is typical for wind-down licenses of the sort referenced (i.e. Ukraine GL 12).

4) See generally Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs