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

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Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

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TURBOFAC Commentary (190 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 (190 words)

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