On August 2, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control issued two general licenses under the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587, related to transactions involving the following blocked entities: Moscow Exchange (“MOEX”), National Clearing Center (“NCC”), and Non-Bank Credit Institution JSC National Settlement Depository (“NSD”). The authorizations in the general licenses also extend to entities in which these companies own a 50 percent or greater interest.
General License 99A temporarily authorizes wind down transactions with these entities as well as certain transactions concerning debt, equity or derivative contracts involving one or more of the specified entities, provided that the payments are made into a blocked account in accordance with the RuHSR. General License 100A temporarily authorizes the divestment of debt or equity to a non-US person or the conversion of currency involving one or more of the specified entities. These transactions are authorized as long as the blocked entity(ies) is acting solely as a securities, trade, or settlement depositor, central counterparty or clearing house, or public trading market. The transactions described in GL 99A and GL 100A are authorized through October 12, 2024.