On July 22, 2020, the Department of the Treasury’s Office of Foreign Assets Control published nine Ukraine and Russia-related Frequently Asked Questions after issuing General License 13O and General License 15I on July 16, 2020, to amend the Ukraine Related Sanctions Regulations (URSR), 31 CFR part 589. GL 13O was issued to authorize certain divestment and transfer activities related to the GAZ Group until January 22, 2021. OFAC issued GL 15I to authorize certain transactions related to the sale and manufacture of vehicles and parts produced by the GAZ Group, and transactions necessary for the maintenance and wind down of certain contracts that involve the GAZ Group until January 22, 2021. The new Frequently Asked Questions issued by OFAC are FAQ 570-571, FAQ 586, FAQ 588-592, and FAQ 625, with each presenting specific scenarios to clarify the implications of each general license.
FAQ 570 and 571 address the provisions of GL 13O. FAQ 570 provides an overview of the general license, while FAQ 571 emphasizes that US persons, in particular, are not authorized to sell, purchase or invest in the debt or equity of GAZ Group, and are not able unblock property under the general license.
FAQ 586 provides a brief overview of GL 15I. FAQ 588-592 all pose questions that discuss the types of transactions in which foreign persons and US persons are authorized to engage, as well as possible sanctions that may be applied should one engage in prohibited activity under GL 15I. Finally, FAQ 625 specifically addresses the term “maintenance” in GL 15I, and provides examples of the types of activities that are considered to be for the maintenance of operations, contracts, or other agreements involving GAZ Group, that are temporarily allowed under the general license.