Yesterday, OFAC replaced Ukraine/Russia-related sanctions General License 13B with 13C, extending the limited timeline for the approved transactions, all related to companies in which Russian oligarch Oleg Deripaska has or had a significant ownership stake, including EN+ Group, GAZ Group and United Company Rusal. The full wording of General License 13C:
DEPARTMENT OF THE TREASURY WASHINGTON, D.C. 20220
OFFICE OF FOREIGN ASSETS CONTROL
Ukraine Related Sanctions Regulations 31 C.F.R. Part 589
GENERAL LICENSE NO. 13C
Authorizing Certain Transactions Necessary to Divest or Transfer
Debt, Equity, or Other Holdings in Certain Blocked Persons
(a) Except as provided in paragraph (d) ofthis general license, all transactions and activities otherwise prohibited by the Ukraine Related Sanctions Regulations, 31 C.F.R. part 589, that are ordinarily incident and necessary (1) to divest or transfer debt, equity, or other holdings in the following blocked persons to a non-U.S. person, or (2) to facilitate the transfer of debt, equity, or other holdings in the following blocked persons by a non-U.S. person to another non-U.S. person, are authorized through 12:01 a.m. eastern daylight time, October 23, 2018:
- GAZ Auto Plant
- Rusal Capital Designated Activity Company
(c) The transactions and activities authorized in paragraphs (a) and (b) include facilitating, clearing, settling transactions to divest to a non-U.S. person debt, equity, or other holdings EN+ Group PLC, GAZ or Company RUSAL or Other Issuer paragraph including on behalf of U.S. persons.
(d) This general license does not authorize:
(1) The unblocking of any property blocked pursuant to any other part of 31 C.F.R. chapter V;
(2) U.S. persons to sell debt, equity, or other holdings to; to purchase or invest in debt, equity, or other holdings in; or to facilitate such transactions with, directly or indirectly, any person whose property and interests in property are blocked pursuant to 31 C.F.R. part 589, including EN+ Group PLC, GAZ Group, or United Company RUSAL PLC, other than purchases of or investments in debt, equity, or other holdings in those persons, or Other Issuer Holdings as described in paragraph (b) (including settlement of purchases or sales that were pending on April 6, 2018), that are ordinarily incident and necessary to the divestment or transfer of debt, equity, or other holdings in EN+ Group PLC, GAZ Group, or United Company RUSAL PLC, or Other Issuer Holdings as described in paragraph (b);
(3) Any transactions or dealings involving the property or interests in property of any person whose property and interests in property are blocked pursuant to 31 C.F.R. part 589 other than EN+ Group PLC, GAZ Group, or United Company RUSAL PLC, or any entity in which those persons have a 50 percent or greater interest consistent with the authorization in paragraph (b) ofthis general license; or
(4) Any transactions or dealings otherwise prohibited by any other part of 31 C.F.R. chapter V.
(e) U.S. persons participating in transactions authorized by this general license are required, within 10 business days after the expiration date of this general license, to file a comprehensive, detailed report of each transaction, including the names and addresses of parties involved, the type and scope of activities conducted, and the dates on which the activities occurred, with the Office of Foreign Assets Control, Office of Compliance and Enforcement, U.S. Department of the Treasury, 1500 Pennsylvania Avenue N.W., Freedman’s Bank Building, Washington, DC 20220, or via email to OFACReport@treasury.gov.
(f) Effective July 31, 201 8, General License No. 13B, dated May 31, 2018, is replaced and superseded in its entirety by this General License No. 13C.