Answer
No. U.S. persons may engage in activities authorized by General License 15I that occur on or after May 22, 2018, except for activities involving blocked persons other than GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) without making associated payments into a blocked account. Similarly, foreign persons may engage in activities that would be authorized by General License 15I if engaged in by a U.S. person without making associated payments into a blocked account.
Date Released
July 22, 2020