On 27 July, the Atlantic Council published a post following recent extension to Gaz-related licences under sanctions regimes administered by OFAC.  It says that, while apparently going unnoticed, they constitute a significant change in the sanctions on Gaz, which can now seemingly operate according to something like business as usual. It reminds one that the Gaz Group was sanctioned for being owned by Oleg Deripaska in April 2018. OFAC also issued 2 general licences to authorise transactions related to divestment from and maintenance or wind-down (termination) of existing business with Gaz; fairly standard for a large company subject to sanctions. The article argues that the most recent, the 9th “extension” on 22 July was not an extension in any sense of the word. Instead, it was an expansion. General License 15I now authorises essentially all business dealings — including new business — with Gaz through late January 2021, with the provisos that assets already frozen must remain frozen and that Gaz must provide regular financial statements and board minutes, as well as certifications that Deripaska has no control over Gaz, to OFAC.

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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