OFAC - Ukraine General License Number 11 - Authorizing Certain Transactions With FAU Glavgosekspertiza Rossii (December 20, 2016)

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TURBOFAC Commentary (198 words)

Notes:

1) FAU Glavgosekspertiza Rossii is a Russian construction company involved in the construction of the Crimea-Russia bridge.

Compare this to Cyber General License (No. 1A), authorizing limited permitting and compliance-related transactions with a state-owned entity designated as an . As there, this GL has no expiration date. As of 5/2019, the entity remains an SDN.

2) By its terms, the GL is not limited to activities in which a U.S. person is a party to an underlying transaction. This means that U.S. persons may engage in ancillary transactions that would be subject to the otherwise-applicable prohibitions, even if such activities pertain to a transaction involving no U.S. person. For example, the U.S. person “facilitation” of transactions between non-U.S. person subsidiaries and the entity is authorized. So are transactions involving the provision of services directly to the covered entity, e.g. the provision of “financial services” to it in connection with a transaction not otherwise involving a U.S. person. Compare e.g. FAQ # 661, comments thereto. See also FR Notice Explaining OFAC's Implementation of Sec. 218 of the (77 FR 75849, Dec. 26, 2012).

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Ukraine General License Number 11 - ​Authorizing Certain Transactions With FAU Glavgosekspertiza Rossii (December 20, 2016)

TURBOFAC Commentary (198 words)

Ukraine General License Number 11 - Authorizing Certain Transactions With FAU Glavgosekspertiza Rossii (December 20, 2016)