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588. I am a U.S. person holding accounts for or other property of GAZ Group or another entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest. Does General License 15K allow me to unblock this property?
No. All accounts or other property of GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest blocked as of May 22, 2018, remain blocked, except for use in the activities authorized in General License 15K. U.S. persons, however, have been permitted to engage in transactions authorized by General License 15K or its predecessors that occurred on or after May 22, 2018, without blocking payments associated with such transactions; however, transactions involving blocked persons other than GAZ Group (including any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) must be blocked.
Date Updated: January 24, 2022
Date Released
July 22, 2020
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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.