December 14, 2018
United Company Rusal PLC (“Rusal”), EN+ Group PLC (“EN+”), JSC EuroSibEnergo (“EuorSib Energo”) and Gaz Group (“Gaz”) 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 a General License, giving U.S. persons until June 5 to wind-down ongoing transactions with the entities, or with any entity in which the designated entities have a 50% or greater interest. Thereafter, OFAC has repeatedly extended the deadline for winding-down transaction with these entities, most recently until January 21, 2019.
To read the full Client Alert, CLICK HERE.