OFAC FAQ (Removed) # 588- Ukraine-/Russia-related Sanctions

Date issued: Jan. 25 2022

TURBOFAC Commentary (150 words)

Notes:

1) Broadly parallel to FAQ 577 (see comments thereto), concerning Rusal, but as of 4/2019 there has not been an agreement to delist GAZ Group as there was with Rusal.

[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) FAQ amended on 7-22-2020 to reflect the expansion of the authorizations in GL 15 as they relate to activities involving GAZ Group (the previous version of the FAQ stated that unblocking of property was only authorized in connection with “maintenance and wind-down”-related activities).

3) FAQ amended on 1-24-2022 to update the number of the GL to the one that was active at the time.

4) FAQ removed between 1-24-2022 and 5-17-2022.