On December 7, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) further extended the expiration date of certain Ukraine-related general licenses related to EN+ Group plc (EN+), United Company RUSAL PLC (RUSAL), and GAZ Group (GAZ) as the entities continue discussions with OFAC to potentially effect “significant changes in control of these sanctioned entities.” The new General Licenses 13H (Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons), 14D (Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with United Company RUSAL PLC), 15C (Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with GAZ Group), and 16D (Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with EN+ Group PLC or JSC EuroSibEnergo) supersede their previous versions by extending the expiration date from from January 7, 2019, to January 21, 2019.
OFAC previously extended the expiration date for General Licenses 13G, 14C, 15B, and 16C to January 7, 2019. See our previous guidance here.
Husch Blackwell’s Export Controls and Economic Sanctions team continues to monitor this situation closely and will provide updates and further analysis as new information becomes available. Should you have any questions, please contact Cortney Morgan, Linda Tiller, or Grant Leach.