OFAC FAQ (Current) # 577- Ukraine-/Russia-related Sanctions

Date issued: Apr. 23 2018

TURBOFAC Commentary (163 words)

Notes:

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.