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578. How did General License 12A differ from General License 12?
General License 12A was amended to reflect the authorization in General License 14. Specifically, U.S. persons were no longer required to place into a blocked account payments to or for RUSAL, or any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest, for activities authorized by General License 14. Activities necessary to the maintenance or wind down of operations or existing contracts of RUSAL and any other entity in which RUSAL owns, directly or indirectly, a 50 percent or greater interest, are authorized pursuant to General License 14 through October 23, 2018. On May 1, 2018, OFAC issued amended General License 12B. See FAQ 583. OFAC issued amended General License 12C on May 22, 2018 to make conforming edits in light of the issuance of General License 15. [05-22-2018]
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) See comment to FAQ 575.