OFAC Notification to Congress of its Intention to Terminate the Sanctions Imposed on En+ Group plc, UC Rusal plc, and JSC EuroSibEnergo

Date issued: Dec. 19 2018

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TURBOFAC Commentary (3739 words)

Notes:

* Update: See full underlying agreement at Agreement Between EN+ Group Plc, UC Rusal, and OFAC on the Terms of Removal of EN+ Group Plc, UC Rusal Plc, and JSC Eurosibenergo From the SDN List.


1) This letter to Congress from OFAC appears to be the only of its kind to be publicized. Section 228 of the CAATSA amends SSIDES to require, when the President elects to terminate sanctions on a person against on which they have been placed, to provide a "a notice of and justification for the termination;" "a notice that...the person is not engaging in the activity that was the basis for the sanctions or has taken significant verifiable steps toward stopping the activity;" and confirmation that "...the President has received reliable assurances...