The U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) has recently issued two new General Licenses to extend pre-existing authorizations for transactions with GAZ Group that would otherwise be prohibited under OFAC’s Ukraine- and Russia-related sanctions. General License 15H (“GL 15H”) authorizes certain activities necessary to maintenance or wind down of operations or existing contracts and certain automotive safety and environmental activities with the Russian automotive conglomerate GAZ Group and its 50%-or-greater-owned subsidiaries. GL 15H, which took effect on March 20, 2020, replaces and supersedes GL 15G and extends the deadline for authorized transactions and activities from March 31, 2020 to July 22, 2020. Any company that engaged in transactions under GL 15G should now reference GL 15H instead.
OFAC also issued General License 13N (“GL 13N”), which replaces and supersedes GL 13M. GL 13N authorizes certain transactions necessary to divest or transfer debt, equity, or other holdings in GAZ Group and its 50%-or-greater-owned subsidiaries. As with the other new license, GL 13N took effect on March 20, 2020 and extends the deadline for companies to divest from GAZ Group to July 22, 2020. Any company that engaged in transactions under GL 13M should now reference GL 13N instead.
Anyone relying on either GL 15H or GL 13N should be aware that each General License imposes certain terms and conditions which must be satisfied in order to qualify for their respective authorizations. Additionally, GL 15H and GL 13N each impose comprehensive and detailed reporting requirements, so persons conducting transactions or activities under GL 15H or GL 13N should document those transactions and activities carefully.