US UKRAINE-/RUSSIA-RELATED GENERAL LICENCES; PUBLICATION OF NEW FAQ

On 23rd April, OFAC issued a news release saying that General License 14 authorises US persons to engage in specified transactions related to winding down or maintaining business with United Company RUSAL PLC (RUSAL) and its subsidiaries until October 23rd 2018.  The FAQ include a clarification that, in accordance with preexisting OFAC guidance,  OFAC will not impose sanctions on foreign persons for engaging in the same activity involving RUSAL or its subsidiaries that General License 14 authorises US persons to engage in​.  OFAC is also issuing another new licence, Ukraine-/Russia-related General License 12A, which replaces and supersedes General License 12 in its entirety.

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20180423.aspx

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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