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575. Why is OFAC issuing General License 14, and what new activity does it authorize?
The purpose of General License 14 is to allow United Company RUSAL PLC (RUSAL) or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest, to continue maintenance or wind down activities until October 23, 2018. Although all funds blocked prior to 12:01 a.m. eastern daylight time, April 23, 2018 remain blocked, the general license authorizes the use of these blocked funds for the maintenance and wind down activities described in General License 14. In addition, U.S. persons are not required to block transactions authorized by General License 14 that occur on or after April 23, 2018, except for transactions involving blocked persons other than RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest. For a discussion of the relationship between General License 14 and foreign persons, please see FAQs 579 and 580.
[04-23-2018]
1) Ukraine GL 14 pertained only to Rusal. That company was de-listed and unblocked as a result of an agreement with OFAC. [1] The 6th iteration of the GL (GLe) has expired, and OFAC has accordingly not extended its validity because all transactions otherwise prohibited with Rusal as a result of the SDN listing are permitted.
[1] See OFAC Notification to Congress of its Intention to Terminate the Sanctions Imposed on En+ Group plc, UC Rusal plc, and JSC EuroSibEnergo, see also https://home.treasury.gov/news/press-releases/sm592, announcing the de-listing.
2) The difference between Ukraine GL 14 and the other Russia-related GLs issued prior to GL 14 is the permission to use blocked funds for wind-down purposes. OFAC typically excludes the use of blocked funds from all company-specific GLs.