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577. I am a U.S. person holding accounts for or other property of RUSAL or another entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest. Does General License 14 allow me to unblock this property?
No. All accounts or other property of RUSAL or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest blocked as of April 23, 2018 remain blocked, except for the use in maintenance and wind-down activities described in General License 14. U.S. persons, however, may engage in transactions authorized by General License 14 that occur on or after April 23, 2018 without blocking payments associated with such transactions, except for transactions involving blocked persons other than RUSAL (including any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest). [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 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. This FAQ clarified that the unblocking permitted in GL 14 was limited to unblocking in connection with activities within the scope of the wind-down license.