OFAC FAQ (Current) # 580 - Ukraine-/Russia-related Sanctions

Date issued: Apr. 23 2018

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TURBOFAC Commentary (447 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) See pertinent interpretive Guidance Letter at Case No. Ukraine-EO13662-2018-354754-1 (2018).

3) Parallel FAQ concerning GAZ Group at FAQ 589.

4) Note that, even without GL 14, foreign persons would have been under no obligation to place funds owed to Rusal...