Ukraine General License Number 16E [REVOKED] - Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with EN+ Group PLC or JSC EuroSibEnergo [PDF Contains all GL Versions]

Date issued: Jan. 16 2019

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TURBOFAC Commentary (574 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) Refer to FAQ 625 and FAQ 626, addressing Ukraine GL 16.

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 that were all designed on the same day. See https://home.treasury.gov/news/press-releases/sm0338.

GL 12 expired June 05, 2018. Some of the substance of the GL...