On November 17, 2022, the UK Office of Financial Sanctions Implementation amended General License INT/2022/2339452 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”). The general license temporarily authorizes Truphone Limited to make or receive payments, subject to certain conditions, to enable the company to continue providing telecommunications services (“Services”) under existing arrangements. The license also allows a Person to undertake any activity necessary to effectively terminate service contracts or obligations. The GL INT/2022/2339452 was originally issued on November 2, 2022 and was amended on November 10 and 17, 2022. The license is effective from November 2, 2022 and expires on April 28, 2023.
Subject to certain conditions, the amended license permits Truphone Limited and its subsidiaries, with the exception of Cellnetrix Technology LLC, (“Company”) to provide and renew Services under existing arrangements, and the Company may recruit new staff and enter into new supply agreements in order to accomplish this. Following the Date of Issue, the license does not permit the provision of new Services to any clients except for certain Incremental Orders and Retail Sales that are provided pursuant to existing agreements with existing customers – agreements that are not considered to be new Services for the purposes of this license.
The amended license also permits the Company to receive £4 million in loan funding into a Truphone Bank Account from a director of the Company pursuant to existing loans executed before the date that the license came into effect, provided that the funds are used only for working capital purposes and other uses permitted in this license. Apart from this particular allowance, the license does not permit the payment or repayment of Company loans and debts by any Person, including designated persons Alexander Grigoryevich Abramov and Alexander Vladimirovich Frolov.
Subject to certain conditions, the amended license also permits the Company to continue to make payments and receive payments due under contractual Service obligations; however, the payments must be received into Truphone Bank Accounts and Subsidiary Bank Accounts. Any payments received by Truphone Limited must be made into a Truphone Bank Account, whereupon it must be frozen, releasable only under this license or another OFSI license. While the amended license also permits Subsidiary Companies to make inter-Subsidiary transfers soley for purposes permitted in this license, all other inter-Company funds must flow to and from Truphone Limited.
The Company is also required to report to OFSI, within 14 days, any payments made under this license with a value over £5,000; the company must also provide complete and readable records of the activity. In addition, any Person who utilizes this general license must keep complete and accurate records of the permitted activity for a minimum of 6 years.