Ukraine General License Number 12C (Expired) - Authorizing Certain Activities Necessary to Maintenance or Wind down of Operations or Existing Contracts (May 22, 2018) [PDF Contains all GL Versions]

Date issued: May. 22 2018

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TURBOFAC Commentary (498 words)

Notes: (PDF Contains all GL Versions)

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