Ukraine General License Number 14E [REVOKED] - Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with United Company RUSAL PLC [PDF Contains all GL Versions]

Date issued: Jan. 16 2019

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TURBOFAC Commentary (595 words)

Notes: (PDF Contains all GL Versions)

*GL revoked in 2020, subsequent to the removal of sanctioned entities at issue from the SDN list.

1) See FAQs and comments thereto for discrete issues raised by the GL: FAQ 575, FAQ 576, FAQ 577, FAQ 579, FAQ 580, FAQ 581, FAQ 592, FAQ 625, FAQ 626.

2) See interpretive Guidance Letter in Case No. Ukraine-EO13662-2018-354754-1 for discussion on relationship between "maintenance" wind-down licenses and secondary sanctions.

3) 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...