OFAC INTENTION TO TERMINATE THE SANCTIONS IMPOSED ON DERIPASKA COMPANIES – EN+ GROUP, RUSAL, AND JSC EUROSIBENERGO – IN 30 DAYS

On 19th December, OFAC announced that it had submitted a notification to Congress of its intention to terminate the sanctions imposed on En+ Group plc, UC Rusal plc, and JSC EuroSibEnergo in 30 days.  The letter lays out the situation, as OFAC sees it, from the initial designations in April, through applications by the 3 companies for delisting and the change in circumstances of the companies.  It provides details of the restructuring agreed by the companies.  However, it says that OFAC will continue to enforce its sanctions on Oleg Deripaska aggressively (he is linked to all 3 companies, they being owned or controlled by, directly or indirectly, Oleg Deripaska and other entities he owns or controls), including by closely monitoring the companies’ compliance with the Terms of Removal agreement.  All of Deripaska’s property and interests in property, including entities in which he holds a 50% or greater interest, will remain blocked, and his investment in these companies is effectively frozen and Deripaska cannot obtain cash either in return for his shares or from future dividends issued by En+, Rusal, or ESE.

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Documents/20181219_notification_removal.pdf

https://home.treasury.gov/news/press-releases/sm576

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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