Ukraine General License Number 15L - Authorizing the Wind Down of Transactions Involving GAZ Group​ (April 25, 2022), Ukraine General License No. 15I [PDF Contains all GL Versions]

Date issued: Apr. 25 2022

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TURBOFAC Commentary (1200 words)

Notes: (PDF Contains all GL Versions)

1) See FAQs and comments thereto for discrete issues raised by the GL: FAQ 586, FAQ 587, FAQ 588, FAQ 589, FAQ 590, FAQ 591, FAQ 592.

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
(GLs 14 and 16 revoked in 2020, subsequent to the removal of sanctioned entities at issue from the SDN list).

GL 12 authorized the wind-down and maintenance of operations with a wide variety of "oligarch-owned" companies that were all designed on the...