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December 19, 2018
The Honorable Mitch McConnell
Majority Leader of the U.S. Senate
Washington, D.C. 20510
Dear Mr. Majority Leader McConnell:
With this letter, we wish to provide you with notification that Treasury intends to terminate the sanctions imposed on En+ Group plc ("En+"), UC Rusal plc ("Rusal"), and JSC EuroSibEnergo ("ESE") in 30 days. En+, Rusal, and ESE have agreed to undertake significant restructuring and corporate governance changes to address the circumstances that led to their designation, including reducing Oleg Deripaska's direct and indirect shareholding stake in those entities to below 50 percent; overhauling the composition of those entities' boards of directors; taking restrictive steps related to their corporate governance; and agreeing to unprecedented transparency by undertaking extensive, ongoing auditing, certification, and reporting requirements. As part of this agreement, half of En+'s restructured board of directors...
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* 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...