U.S. Department of the Treasury

No.  GL 13D  authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, Russia-related Directive 4 Entities) that would otherwise be prohibited by Russia-related Directive 4 under Executive Order 14024 (the Russia-related Sovereign Transactions Directive ), provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation.  This so-called “exit tax” is not considered ordinarily incident and necessary to day-to-day operations in the Russian Federation and, thus, not authorized under GL 13D.  Pursuant to the Russia-related Sovereign Transactions Directive, U.S. persons are prohibited from engaging in direct or indirect transactions involving any Russia-related Directive 4 Entity.  Please see Frequently Asked Question 1002 .  In light of the potential for the payment of this so-called “exit tax” to involve a Russia-related Directive 4 Entity, U.S. persons whose divestment will involve an “exit tax” payment may require a license from OFAC.  Such persons may submit a request for a specific license with OFAC’s Licensing Division online at http://www.home.treasury.gov/policy-issues/financial-sanctions/ofac-license-application-page.  OFAC will evaluate such requests on a case-by-case basis.