On May 1, 2018, the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Ukraine- and Russia-related general licenses, along with new and revised FAQs relating to these general licenses.

General License 12B, which entirely replaces General License 12A, “permits originating and intermediary U.S. financial institutions to process funds transfers that they would otherwise block to an account held by a blocked U.S. person at a U.S. financial institution.  In addition, General License 12B clarifies that U.S. financial institutions can release such funds for authorized maintenance and wind-down purposes.”

General License 13A, which entirely replaces General License 13, “authorizes transactions and activities necessary to divest or transfer debt, equity or other holdings in EN+ Group, GAZ Group, or United Company RUSAL PLC.  General License 13A also authorizes such transactions in entities in which those persons own, directly or indirectly, a 50 percent or greater interest, provided that such debt, equity, or other holdings were issued by Irkutskenergo, GAZ Auto Plant, or Rusal Capital Designated Activity Company.”

OFAC has also issued three new FAQs and several revisions of existing FAQs about these general licenses.

The OFAC publication may be found here:

https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20180501.aspx

The FAQs may be found here:

https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_other.aspx#ukraine