January 28, 2019
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”). Those designations meant that U.S. persons generally could not engage in any transactions with the three entities and that foreign persons could not 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 28, 2019.
To read the full Client Alert, click HERE.