On March 20, 2020, the US Department of Treasury’s Office of Foreign Asset Control extended the expiration dates for two general licenses related to the GAZ Group that allow the following transactions that are otherwise prohibited by the Ukraine Related Sanctions Regulations, 31 C.F.R. part 589:
The Ukraine-related General License No. 13N – “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group,” allows all transactions necessary to enable a US person to divest or transfer debt, equity or other interests in the GAZ Group to a non-US person until July 22, 2020. The extension also applies to any entity where GAZ Group owns a 50 percent or greater interest, that was issued by GAZ Auto Plant to a non-US person. The above transactions include those made to non-US persons on behalf of US persons; however, any US person that participates in a 13N transaction must file a detailed report with OFAC within 10 business days after the general license expires.
The Ukraine-related General License No. 15H – “Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with GAZ Group, and Certain Automotive Safety and Environmental Activities,” allows all transactions necessary to maintain or wind down operations of the GAZ Group or any entity where the GAZ Group owns a fifty percent or greater interest. It allows for the research and development of Electronic Stability Program systems and Euro 5/6 emissions standards for vehicles produced by GAZ Group. It also allows for the installation of occupant safety systems in vehicles produced by the GAZ Group. All of these activities are allowed until July 22, 2020, and any US person participating in a 15H transaction must file a detailed report with OFAC within 10 business days after the expiration date of the general license expires.