Frequently Asked Questions

Yes, GL 15L authorizes U.S. persons to receive regularly scheduled payments of principal and interest from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) only to the extent such transactions are ordinarily incident and necessary to the wind down of transactions involving GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) through 12:01 a.m. eastern daylight time, May 25, 2022, and provided the other terms and conditions of GL 15L are met.  As a general matter, GL 15L also would authorize U.S. persons to receive accelerated payments or voluntary prepayments from GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) so long as such accelerated payments or voluntary prepayments were ordinarily incident and necessary to the wind down of transactions as authorized by GL 15L.  However, GL 15K does not authorize U.S. persons to send accelerated payments or voluntary prepayments to GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest).  If you are unsure about whether GL 15L authorizes such accelerated payments or voluntary prepayments, you may contact OFAC.

Date Updated: April 25, 2022

 

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GL 15L authorizes transactions and activities that are ordinarily incident and necessary to the wind down of transactions involving GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest), including exports.  Any exports to GAZ Group must be consistent with GL 15L and must also be consistent with the requirements of other U.S. federal agencies.  After the expiration of GL 15L, unless exempt or authorized by OFAC, U.S. persons will be prohibited from engaging in any transactions (including those related to wind down and exports) involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and must block property or interests in property of such persons that are in, or come within, the United States, or the possession or control of a U.S. person.

Date Updated: April 25, 2022

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No.  U.S. persons may engage in activities authorized by GL 15L 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 GL 15L if engaged in by a U.S. person without making associated payments into a blocked account.

Date Updated: April 25, 2022

 

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As described in FAQs 542, 545, 574, and 579, a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, if a U.S. person would not require a specific license from OFAC to participate in such a transaction.  Therefore, activity authorized by General License (GL) 15L, and occurring within the time period authorized by GL 15L, would not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA.

Date Updated: April 25, 2022

 

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GL 15L superseded GL 15K on April 25, 2022.  While GL 15K authorized certain transactions and activities that were ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and that were in effect prior to April 6, 2018, GL 15L only authorizes certain transactions and activities that are ordinarily incident and necessary to the wind down of transactions involving GAZ Group and any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. eastern daylight time, May 25, 2022.

All funds blocked prior to 12:01 a.m. eastern daylight time, May 22, 2018, remain blocked.  Unlike its predecessors, this general license no longer authorizes the use of these blocked funds for the activities it authorizes.  In addition, U.S. persons have not been required to block transactions authorized by GL 15L or its predecessors that occurred on or after May 22, 2018; however, transactions involving blocked persons other than GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, must be blocked.  For information regarding the relationship between GL 15L and foreign persons, please see FAQs 589 and 590.

After the expiration of GL 15L, unless exempt or authorized by OFAC, U.S. persons will be prohibited from engaging in transactions involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and must block property or interests in property of such persons that are in, or come within, the United States, or the possession or control of a U.S. person.

Date Updated: April 25, 2022

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No.  Until 12:01 a.m. eastern daylight time, May 25, 2022, GL 13R authorizes certain divestment and transfer activities related to debt, equity, or other holdings in GAZ Group, or in entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, that were issued by GAZ Auto Plant (“Other Issuer Holdings”), subject to certain conditions and exceptions.  It does not authorize U.S. persons to sell debt, equity, or other holdings to; to purchase or invest in debt, equity, or other holdings in; or to facilitate such transactions with, directly or indirectly, GAZ Group or any other blocked person, other than transactions and activities involving GAZ Group, or entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest that are ordinarily incident and necessary to the divestment or transfer of debt, equity, or other holdings in these entities.

GL 13R superseded GL 13Q on April 25, 2022.  After the expiration of GL 13Q, U.S. persons will be prohibited from engaging in any divestment or transfer activities on behalf of U.S. persons or non-U.S. persons related to debt, equity, or other holdings that previously were authorized by GL 13Q.

Date Updated: April 25, 2022

 

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Until 12:01 a.m. eastern daylight time, May 25, 2022, General License (GL) 13R authorizes certain divestment and transfer activities related to debt, equity, or other holdings in GAZ Group, or in entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, that were issued by GAZ Auto Plant (“Other Issuer Holdings”), subject to certain conditions and exceptions.  Specifically, GL 13R authorizes U.S. persons to divest or transfer to a non-U.S. person, or to facilitate the transfer by a non-U.S. person to another non-U.S. person, debt, equity, or other holdings in GAZ Group or Other Issuer Holdings as described in GL13R.  However, such divestment, transfer, or facilitation must not result in U.S. persons selling debt, equity, or other holdings to; purchasing or investing in debt, equity, or other holdings in; or facilitating such transactions with, directly or indirectly, any blocked person, including GAZ Group, other than transactions and activities involving GAZ Group, or entities in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest that are ordinarily incident and necessary to the divestment or transfer of debt, equity, or other holdings in the entities identified in GL 13R.  Please see GL 13R for further details.

GL 13R superseded GL 13Q on April 25, 2022.  After the expiration of GL 13R, U.S. persons will be prohibited from engaging in any divestment or transfer activities on behalf of U.S. persons or non-U.S. persons related to debt, equity, or other holdings that previously were authorized in GL 13R.

Date Updated: April 25, 2022

 

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