OFAC extends wind-down deadline for dealings with sanctioned Russian companies

The US Department of the Treasury’s Office of Foreign Assets Control (‘OFAC’) has issued two new general licences extending the expiry date for certain dealings with GAZ Group and other sanctioned Russian entities from 23 October until 12 December 2018. The new licences are General License No 13F and General License No 15A.

General License No 13F allows US persons to divest or transfer debt, equity or other holdings in blocked companies including EN+ Group, RUSAL and GAZ Group until 12 December 2018.

General License No 15A authorises those activities necessary to the ‘maintenance or wind down’ of operations or existing contracts with GAZ Group until 12 December 2018.

The licences also cover transactions involving holdings where the sanctioned parties have an indirect or direct ownership of 50% or more.

The Russian companies were impacted by targeted US sanctions on Oleg Deripaska in April 2018 in response to the ‘malign activity’ of the Russian state, including suspected meddling in the 2016 US presidential election. Deripaska was until recently president of RUSAL and EN+ Group and is a significant stakeholder in GAZ Group.

OFAC recently extended the expiry date for three general licences allowing certain transactions with EN+ Group and RUSAL until 12 December 2018 to review proposed ‘corporate governance changes that could potentially result in significant changes in control.’

General License 13F can be found here:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/ukraine_gl13f.pdf

General License 15A can be found here:
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/ukraine_gl15a.pdf

OFAC’s Notice can be found here:
https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20181019.aspx