July 17, 2020

OFAC amends two Ukraine-related general licenses

On July 16, 2020, The Department of the Treasury’s Office of Foreign Assets Control amended two general licenses in the Ukraine Related Sanctions Regulations (URSR), 31 CFR part 589.  General license 13O was issued to authorize all transactions that are necessary to transfer debt or equity in the GAZ Group to a non-US person or by non-US person to another non-US person, until January 22, 2021.  It also allows all transactions that are necessary to transfer debt or equity in entities in which GAZ Group owns a direct or indirect 50 percent or greater interest, that was issued by the GAZ Auto Plant, to a non-US person or by a non-US person to another non-US person, until January 22, 2021.  This includes transactions to divest debt or equity in GAZ Group to a non-US person, including on behalf of US persons.  Any US person participating in any transaction authorized by this general license is required to file a detailed report of each transaction with OFAC, within 10 days of the expiration date of this license.  General license 13O replaces and supersedes General License No. 13N, dated March 20, 2020 in its entirety.

OFAC also amended general license 15I in the URSR, to authorize certain activities that are necessary for the sale and manufacture of existing and new models of vehicles and vehicle parts produced by the GAZ Group, or any entity in which the GAZ Group owns a direct or indirect 50 percent or greater interest, until January 22, 2021.  It also allows, until January 22, 2021, all transactions that are necessary to maintain or wind down operations and contracts involving the GAZ Group or any entity in which the GAZ Group owns a direct or indirect 50 percent or greater interest, that was in effect prior to April 6, 2018.  GL 15I also authorizes the use of funds in accounts that were blocked as of May 22, 2018, for activities authorized by this general license.  Any US person participating in any transaction authorized by this general license is required to file a detailed report of each transaction with OFAC, within 10 days of the expiration date of this license. General License 15I replaces and supersedes General License 15H, dated March 20, 2020, in its entirety.

OFAC News Bulletin | OFAC Ukraine Sanctions Regulations – GL 13O | OFAC Ukraine Sanctions Regulations – GL 15I