January 4, 2019
Introduction
United Company Rusal PLC (“Rusal”), EN+ Group PLC (“EN+”) and JSC EuroSibEnergo (“ESE”) were all named to the U.S. Specially Designated Nationals List (“SDN List”) on April 6, 2018 by the U.S. Office of Foreign Asset Control (“OFAC”). These designations mean that U.S. persons generally cannot engage in any transactions with these entities and that foreign persons cannot engage in “significant transactions.” However, simultaneous with the April 6 designations, OFAC issued a General License, giving U.S. persons until June 5 to wind-down ongoing transactions with the entities, or with any entity in which they have a 50% or greater interest. Thereafter, OFAC has repeatedly extended the deadline for winding-down transactions with these entities, most recently until January 21, 2019.
OFAC announces intention to remove Rusal, EN+ and ESE from SDN List
On December 19, 2018 OFAC sent a lengthy letter to the U.S. Congress, advising that within 30 days it intended to remove from the SDN List Rusal, EN+ and ESE.
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