October 15, 2018

United Company Rusal PLC (“Rusal”), EN+ Group PLC (“EN+”) and JSC EuroSibEnergo (“EuorSib Energo”) 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 those entities and that foreign persons cannot engage in “significant transactions.” However, simultaneous with the April 6 designations, OFAC issued General License 12, giving U.S. persons until June 5 to wind-down ongoing transactions with the three entities, or with any entity in which the three designated entities have a 50% or greater interest. Thereafter, as reported in our Client Alerts of April 24 and September 27, 2018, OFAC issued General License 14 extending the Rusal wind-down period until October 23 and General License 14A, granting a further extension until November 12. OFAC also issued General Licenses 16 and 16A, also extending the time for U.S. persons to wind-down operations, contracts or other agreements with EN+ and EuroSibEnergo, or any entity of which either owns 50% or more, until October 23, and then until November 12, 2018.

To read the full Client Alert, click HERE.