Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses

The Office of Foreign Assets Control (OFAC) has published a press release to announce extensive new sanction measures to impose further restrictions on individuals and entities (including ships) engaged in or used for the purchase of goods for the benefit of the Russian military. Specifically, OFAC is designating numerous additional individuals, entities, and vessels in accordance with amended Executive Order (E.O.) 14024 which permits the sanctioning of „Harmful Foreign Activities“ performed and conducted by the Russian government, the military, entities, or persons. OFAC is also modifying the records of some entities and persons already contained on its Specially Designated Nationals (SDN) list. As the number of firms, individuals, bodies, and vessels is VERY large (>150), we refrain from listing them individually at this point. Please refer to the enclosed document or follow above noted link for more information on their names, dates of birth, place of residency, and other relevant information, each if applicable.
Also, OFAC has published an accompanying statement to explain the reasoning behind the latest designations.
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Finally, OFAC has issued two new general licenses to permit (financial) transactions that would otherwise be prohibited by Executive Order 14024. These are:
(1) General License 79 which authorizes (financial) transactions for the purpose of winding down ongoing activities with the following firms or any entity in which the noted firms have ownership interest of 50% or more:
– Limited Liability Company Kyiv Square;
– Highland Gold Mining Limited;
– Limited Liability Company Kismet Capital Group.
(2) General License 80 which authorizes „Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Highland Gold Mining Limited“ or any entity owned or controlled by such (ownership interest must be 50% or more) for the purpose of divestment or transfer of such securities. One key condition is that related security transaction must have been initiated prior to December 12, 2023 at 4:00 p.m. Eastern Daylight Time.
The licenses also stipulate other conditions that must be observed in the context of benefiting from these licenses and are time limited. Please review the original licenses for more detailed information in this matter.