Morgan Lewis US and Russia Sanctions Update
US Direct Sanctions - SDNS (cont'd)
Dealing with SDNs: Guidance, Licensing, etc.
See the related OFAC 6 April, 23 April FAQS 567-582 and more on 1, 22 and 25 May,
and 14 Sept. 2018 (FAQS 625 and 626 - see below), as further amended on 22 July
2020 giving guidance to US persons re continued relations with such designated
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SDN companies (or those also covered by the 50% rule) or individuals, including:
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Employment by or board service at such a company
Purchase/import of goods from such a company
Ownership of such a company's shares or GDRs
Holding accounts or other property of such a company or individual
And note the most recent OFAC FAQ re "maintenance" of operations, contracts etc.
with GAZ Group (and their subs)
This is FAQ 625 (as amended July 2020, from initial 2018 issuance that applied to all the
then-designated Deripaska-controlled companies)
which refers specifically to the relevant General License re GAZ
may well also have more general application in other analogous GL-based maintenance/wind-down
situations - so important to review / have in mind
but caution is needed - OFAC and/or BIS or State Dep't guidances, restrictions and permissions
(contained in GLS, FAQs, regulations etc.) stated in one document in the context of one sanctions
program cannot automatically be applied/relied on in the context of a different-country and/or
different agency program
Morgan Lewis
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