September 27, 2018
In our Client Alert of April 12, 2018, we reported that on April 6, 2018, the United States Office of Foreign Asset Controls (“OFAC”) designated 12 Russian companies, including United Company Rusal PLC (“Rusal”) to the U.S. Specially Designated Nationals List (“SDN List”). Rusal is one of the world’s largest producers of aluminum and a major shipper of both raw products and finished materials. At the same time as the April 6, 2018, designation of Rusal to the SDN List, OFAC also issued General License No. 12, which gave U.S. persons until June 5, 2018, to wind-down ongoing transactions with Rusal.
Thereafter, in our Client Alert of April 24, 2018, we reported that on April 23, 2018, OFAC issued General License 14, which extended the time for U.S. persons to wind-down operations, contracts or other agreements with Rusal, or any entity of which Rusal owns greater than 50%, until 12:01 a.m. eastern standard time on October 23, 2018.
To read the full Client Alert, click here.