New US Russia general licences & FAQs

OFAC3

Following US sanctions imposed on a number of Russians on 6 April 2018 (previous blog), OFAC has issued 2 new Ukraine/Russia-related general licences:

  1. General License 15, which authorises US persons to engage in specified transactions related to winding down or maintaining business with GAZ Group and its subsidiaries until 23 October 2018.
  1. General License 12C, which replaces and supersedes General License 12B (previous blog) in its entirety. General License 12C “permits originating and intermediary U.S. financial institutions to process funds transfers that they would otherwise block to an account held by a blocked U.S. person at a U.S. financial institution. In addition, General License 12C clarifies that U.S. financial institutions can release such funds for authorized maintenance and wind-down purposes.”

OFAC has also published 6 new FAQs and revised existing FAQs relating to these general licences. See OFAC Notice here.

This entry was posted in Russia, USA by Maya Lester QC. Bookmark the permalink.

About Maya Lester QC

Maya Lester QC has a wide ranging practice in public law, European law, competition law, international law, human rights & civil liberties. She has a particular expertise in sanctions. As the most recent (2016) Chambers & Partners directory put it, she "owns the world of sanctions". She spent 2011-12 in New York at Columbia Law School lecturing and writing on sanctions. She represents and advises hundreds of companies and individuals before the European and English courts and has acted in most of the leading cases, including Kadi, Tay Za, Central Bank of Iran, NITC and IRISL.

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