In light of the recent US sanctions on a number of Russian oligarchs, government officials and entities (previous blog), OFAC has issued (1 May 2018) Ukraine/Russia-related General Licence 12B, which replaces and supersedes General Licence 12A. General Licence 12B now permits originating and intermediary US financial institutions to process funds transfers that they would otherwise block to an account held by a blocked US person at a US financial institution. The licence also clarifies that US financial institutions can release such funds for authorised maintenance and wind-down purposes.
OFAC has also issued Ukraine/Russia-related General Licence 13A, which replaces and supersedes General Licence 13. General Licence 13A extends the original term of General Licence 13 through to 5 June 2018 (previously 7 May), and authorises transactions and activities necessary to divest or transfer debt, equity or other holdings in EN+ Group, GAZ Group, or United Company RUSAL PLC. The licence also authorises such transactions in entities in which those persons own (directly or indirectly) a 50% or greater interest, provided that such debt, equity, or other holdings were issued by Irkutskenergo, GAZ Auto Plant, or Rusal Capital Designated Activity Company.
Michael was called to the Bar in 1992 and prior to joining Peters & Peters was a senior specialist prosecutor at the Crown Prosecution Service Headquarters (CPS). He was a key member of a small specialist unit responsible for the prosecution of serious and high-profile fraud, terrorist,...See profile for Michael O'Kane >