The Department of the Treasury's Office of Foreign Assets Control (OFAC) has announced its extension of two general licenses related to GAZ Group, Ukraine-related  General License No. 13Q, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group” and Ukraine-related  General License No. 15K, “Authorizing Certain Activities Involving GAZ Group” until April 27, 2022. OFAC's 90-day extension of both licenses is shorter than the previous extensions for one-year periods.

Effective January 24, 2022, General License 13Q supersedes and replaces General License 13P, dated December 23, 2020. General License 13Q authorizes all transactions and activities otherwise prohibited by Ukraine Related Sanctions Regulations, 31 C.F.R. Part 589 (“URSR”), that are ordinarily incident and necessary to:

  • divest or transfer debt, equity, or other holdings in GAZ Group or in entities in which GAZ Group owns, directly or indirectly, a 50% or greater interests to a non-U.S. person, or
  • facilitate the transfer of debt, equity, or other holdings in GAZ Group or in entities in which GAZ Group owns, directly or indirectly, a 50% or greater interests by a non-U.S. person to another non-U.S. person.

Similarly, effective January 24, 2022, General License 15K supersedes and replaces General License 15J, dated December 23, 2022. General License 15K authorizes, through April 27, 2022, all transactions and activities otherwise prohibited by the URSR that are ordinarily incident and necessary to:

  • the manufacture and sale of existing and new models of vehicles, components, and spare parts, including automobiles, light commercial vehicles, trucks, buses, engines/powertrains produced by GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and
  • the maintenance or wind down of operations, contracts, or other agreements, including the importation of goods, services, or technology into the United States, involving GAZ Group, or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and that were in effect prior to April 6, 2018.

Both General Licenses 13Q and 15K require that on or before 10 business days after the expiration of the license, all U.S. persons participating in transactions authorized by this general license file a comprehensive, detailed report with OFAC.

General Licenses 13Q and 15K expire on April 27, 2022 at 12:01 a.m. EST.  In addition, OFAC has amended several Ukraine-related  Frequently Asked Questions.

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