Russia-related Designations; Issuance of Russia-related General Licenses and Frequently Asked Question; Revocation of Russia-related General License

In view of the ongoing aggression of Russia towards Ukraine, the U.S. Department of the Treasury has drawn up a new sanctions package targeting Russia, the Russian economy, and Russian firms and individuals, which consists of the following:
(1) The sanctioning of an additional 34 individuals, 91 entities, and numerous vessels for their engagement in or support of the Russian war against Ukraine. As the number of sanctioned persons, firms, and ships is very large, we refrain from listing them individually at this point. For details on their names, dates of birth (if applicable), places of residency, or other identifying information, please refer to the corresponding press release published by the Treasury’s Office of Foreign Assets Control, OFAC.
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(2) The modifications of the records of one already sanctioned individual and entity whose records now read as follows:
DESYATOVA, Natalya Leonidovna (Cyrillic: ДЕСЯТОВА, Наталя Леонідівна; Cyrillic: ДЕСЯТОВА, Наталья Леонидовна) (a.k.a. DESIATOVA, Natalia; a.k.a. LYUTOVA, Nataliya Leonidivna (Cyrillic: ЛЮТОВА, Наталія Леонідівна); a.k.a. LYUTOVA, Nataliya Leonidovna (Cyrillic: ЛЮТОВА, Наталия Леонидовна)), 122 Ilyushi Kulika St., Apartment 89, Kherson, Kherson region 7300, Ukraine; DOB 11 Jul 1966; nationality Ukraine; Gender Female; Tax ID No. 2429802748 (Ukraine) (individual) [RUSSIA-EO14024]. -to- DESYATOVA, Natalya Leonidovna (Cyrillic: ДЕСЯТОВА, Наталя Леонідівна; Cyrillic: ДЕСЯТОВА, Наталья Леонидовна) (a.k.a. DESIATOVA, Natalia; a.k.a. LYUTOVA, Nataliya Leonidivna (Cyrillic: ЛЮТОВА, Наталія Леонідівна); a.k.a. LYUTOVA, Nataliya Leonidovna (Cyrillic: ЛЮТОВА, Наталия Леонидовна)), 122 Ilyushi Kulika St., Apartment 89, Kherson, Kherson region 73009, Ukraine; DOB 11 Jul 1966; nationality Ukraine; Gender Female; Tax ID No. 2429802748 (Ukraine) (individual) [RUSSIA-EO14024].
LIMITED LIABILITY COMPANY KALEIDOSKOP (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ КАЛЕЙДОСКОП), House 2, Building 2, Paveletskaya square, Moscow 115054, Russia; Organization Established Date 09 Dec 2016; Tax ID No. 770501001 (Russia); Registration Number 5167746427063 (Russia) [RUSSIA-EO14024]. -to- LIMITED LIABILITY COMPANY KALEIDOSKOP (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ КАЛЕЙДОСКОП), House 2, Building 2, Paveletskaya square, Moscow 115054, Russia; Organization Established Date 09 Dec 2016; Tax ID No. 9705083235 (Russia); Registration Number 5167746427063 (Russia) [RUSSIA-EO14024].
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(3) The issuance of four new General Licenses and the revocation of an existing one: In order to provide U.S. firms and individuals with an opportunity to adequately deal with the new sanction measures, OFAC has issued several new General Licenses in this context. These consist of the following:
New General License (GL 62) permits the wind-down of transactions involving the newly sanctioned firms Holdingovaya Kompaniya Metalloinvest AO (Metalloinvest), Megafon PAO (Megafon), Limited Liability Company USM Telecom (USM Telecom), Akkermann Cement Ca Limited Liability Company (Akkermann), or any firms controlled or owned by such (50% or more).
New General License (GL 63) permits the wind-down (sale / divestment) of securities (debt and equity) and derivatives involving newly sanctioned Holdingovaya Kompaniya Metalloinvest AO or any firms controlled or owned by such (50% or more).
New General License (GL 64) permits certain (financial) transactions involving Kommersant or any firms controlled or owned by such (50% or more). „Certain“ includes those transactions that are „ordinarily incident and necessary to the operations of the newspaper Kommersant.
New General License (GL 65) permits certain (financial) transactions involving Megafon PAO (Megafon) or Digital Invest Limited Liability Company (Digital Invest) or any firms controlled or owned by such (50% or more). „Certain“ includes those transactions that are „ordinarily incident and necessary to the receipt or transmission of telecommunications“ and transactions involving the sale, export, and supply of „software, hardware, or technology incident to the exchange of communications over the internet, such as instant messaging, videoconferencing, chat and email,“ etc.
Revoked General License (GL 15) no longer permits ANY (financial) transactions involving Alisher Burhanovich Usmanov or any firms or entities owned or controlled by the person.
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(4) The issuance of one new FAQ: OFAC has also published one new frequently asked question (FAQ) related to the new sanction measures and the licenses which reads as follows:
FAQ 1122: Certain transactions related to telecommunications and certain internet-based communications are already authorized by Russia-related General License (GL) 25C. What additional transactions does Russia-related GL 65 authorize?
The United States generally supports the free flow of information globally as facilitated by telecommunications and certain internet-based communications. Accordingly, GL 25C authorizes — with certain exceptions and exclusions — (i) all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR) and (ii) the exportation or reexportation, sale, or supply from the United States or by U.S. persons, wherever located, to the Russian Federation of services, software, hardware, or technology that are incident to the exchange of communications over the internet and that are prohibited by the RuHSR (see FAQ 1040).
However, certain transactions related to Megafon PAO (Megafon) or Limited Liability Company Digital Invest (Digital Invest) — which were designated by the Department of State on April 12, 2023 pursuant to Executive Order 14024 — or any entity in which Megafon or Digital Invest owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest (collectively, “Covered Entities”), may not involve the Russian Federation, and thus, may not be authorized by GL 25C. To ensure certain transactions related to telecommunications and internet-based communications involving the Covered Entities and Tajikistan or Uzbekistan can continue, OFAC issued GL 65. GL 65 authorizes — with certain exceptions and exclusions — (i) all transactions prohibited by the RuHSR that are ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Covered Entities, and involving Tajikistan or Uzbekistan or (ii) the exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons, wherever located, to the Covered Entities of services, software, hardware, or technology incident to the exchange of communications over the internet that is prohibited by the RuHSR. Please note that GL 65 does not relieve persons from compliance with other Federal laws, such as the export licensing requirements maintained by the Department of Commerce’s Bureau of Industry and Security.
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Finally, OFAC has published an accompanying press statement to provide more detailed information on these sanction measures.