On December 19, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) submitted a letter to congressional leaders (“Congressional Letter”) notifying Congress of its intent to terminate the sanctions imposed on En+ Group plc (“En+”), UC Rusal plc (“RUSAL”), and JSC EuroSibEnergo (“ESE”) in 30 days. On the same day, OFAC announced new sanctions against a number of individuals and entities for their involvement in a range of malign activities. Concurrently, the US Department of State announced it had added 12 individuals and entities to the List of Specified Persons under Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) for being part of, or operating for or on behalf of, the defense or intelligence sector of the Russian Federation.
Extension of General Licenses
On November 9, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) temporarily extended the expiration dates of four general licenses related to EN+ Group PLC (“EN+”), United Company RUSAL PLC (“RUSAL”), and GAZ Group (“GAZ”) from December 12, 2018 to January 7, 2019. Please see our blog posts on the original designation of these companies and previous extensions of these general licenses here and here. The Treasury Department press release indicates that EN+, RUSAL, and GAZ are proposing substantial corporate governance changes that could potentially result in significant changes in control and ultimately lead to these entities’ removal from the Specially Designated Nationals and Blocked Persons List (“SDN List”).