Russian Harmful Foreign Activities General License 3 - Authorizing the Wind Down of Transactions Involving State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (February 22, 2022)

Date issued: Feb. 22 2022

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TURBOFAC Commentary (273 words)

Notes:

1) This is one of five GLs that apply to Vnesheconombank. Russian Harmful Foreign Activities General License 2 (no expiration date) is for the servicing of sovereign debt that is not subject to Directive 1A Under Executive Order 14024. See also Russia-related GL 8 (energy), Russia-related GL 9 (debt/equity), and Russia-related GL 10 (derivatives).

2) This is a standard wind-down general license, authorizing the processing of underlying transactions that may not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities. See designation press release at https://home.treasury.gov/news/press-releases/jy0602.

3) Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this....