OFAC extends Ukraine-related general licenses for Gaz Group

On  November 1, 2019, the Office of Foreign Assets Control of the US Department of the Treasury issued amended Ukraine-related general licenses.  Specifically, OFAC extended the expiration date of two general licenses relating to GAZ Group, a Russian producer of motor vehicles and automotive components, by replacing and superseding General Licenses 13L and 15F.

General License 13M, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group,” authorizes transactions that would otherwise be prohibited by the Ukraine Related Sanctions Regulations, 31 CFR part 589, that are incident to the  transfer of GAZ Group holdings to a non-US person, or to facilitate the transfer of GA Group holdings by one non-US person to another, until March 31, 2020.  GL 13M does not authorize the unblocking of any blocked property, and entails a reporting requirement for US persons participating in the transactions it permits.

General License 15G, “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with GAZ Group, and Certain Automotive Safety and Environmental Activities,” authorizes transactions otherwise prohibited by 31 CFR part 589 that are incident to maintenance or winding down pre-existing operations and contracts involving GAZ Group or entities it owns, as well as research and development regarding automobile safety and emissions standards.  The general license does unblock previously blocked funds except for their use in connection with the activities authorized by the general license.  US persons participating in transactions authorized by GL 15G must report the transactions within 10 business days after the expiration date of the general license on March 31, 2020.
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