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OFFICE OF FOREIGN ASSETS CONTROL
Ukraine Related Sanctions Regulations
31 C.F.R. Part 589
GENERAL LICENSE NO. 12C
Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts
(a) Except as provided in paragraph (d) of this general license, all transactions and activities otherwise prohibited by the Ukraine Related Sanctions Regulations, 31 C.F.R. part 589, that are ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements, including the importation of goods, services, or technology into the United States, involving one or more of the following blocked persons and that were in effect prior to April 6, 2018, are authorized through 12:01 a.m. eastern daylight time, June 5, 2018:
• AgroHolding Kuban
• Basic Element Limited ...
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1) See interpretive Guidance Letter in Case No. Ukraine-EO13662-2018-354754-1 for discussion on relationship between this type of license and Russia-related secondary sanctions.
2) See FAQs and comments thereto for discrete issues raised by the GL: FAQ 567, FAQ 569, FAQ 578, FAQ 582, FAQ 583, FAQ 592.
3) This license was issued soon after OFAC designated, on the same day, a wide variety of "oligarch-owned" companies. See https://home.treasury.gov/news/press-releases/sm0338.
4) COMMON NOTE ON THE RELATIONSHIP BETWEEN UKRAINE GL 12, UKRAINE GL 13, UKRAINE GL 14, UKRAINE GL 15, AND UKRAINE GL 16
GL 12 authorized the wind-down and maintenance of operations with a wide variety of "oligarch-owned" companies that were all designed on the same day. See