Case No. Ukraine-EO13662-2018-354754-1 - [Application Included in Original PDF]

Date issued: Jul. 18 2018

Last substantive commentary amendment:
Jun. 12 2023

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TURBOFAC Commentary (1047 words)

Notes:

1) On the basis of the description of the application (attached in original PDF), this guidance appears to clarify that, as opposed to a "wind down" license, a "maintenance or wind down" General License permits what would effectively be business as usual. The apparent reason for the provision for "maintenance" with respect to Ukraine GL 12, Ukraine GL 14, Ukraine GL 15 and Ukraine GL 16 is that they all pertain to companies owned or controlled by a single SDN reported to have been in the process of divesting his stake in the companies at issue. See other documents categorized "wind down" for the scope of an ordinary wind down license.

2) Read in conjunction with FAQ 625 and FAQ 626, issued after this guidance letter, which further clarify the scope...