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Financial Services Law Insights and Observations

OFAC issues new Ukraine-/Russia-related general licenses and updated FAQs

Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury Ukraine Russia OFAC Sanctions OFAC Designations

Financial Crimes

On April 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Ukraine-/Russia-related General License (GL) 13R, “Authorizing the Wind Down of Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group,” which authorizes all transactions ordinarily incident and necessary to the wind down of certain transactions by a non-U.S. person to another non-U.S. person through May 25, provided certain criteria are met. OFAC also issued GL 15L, “Authorizing the Wind Down of Transactions Involving GAZ Group,” which also authorizes certain transactions ordinarily incident and necessary to the wind down of transactions involving the GAZ Group, or any entity in which the GAZ Group owns, directly or indirectly, a 50 percent or greater interest. This wind down period also goes through May 25. Additionally, OFAC updated several related frequently asked questions about Ukraine-/Russia-related sanctions.