On March 20, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) extended the expiration dates of two general licenses related to GAZ Group (“GAZ”), which was designated as an SDN on April 6, 2018 for being owned or controlled by Oleg Deripaska.  Please see our blog post regarding this designation here, and our blog about the previous extension of these general licenses here.  At the same time, OFAC expanded one of the general licenses. 

The GAZ-related general licenses were extended (and in one case expanded) as follows:

  • General License No. 13N (“GL 13N”) was issued to replace and supersede in its entirety General License No. 13M. GL 13N continues to authorize certain transactions by US persons ordinarily incident and necessary to divest or transfer debt, equity, or other holdings in GAZ to non-US persons, but extends the deadline from March 31, 2020 to July 22, 2020
  • General License No. 15H (“GL 15H”) was issued to replace and supersede in its entirety General License No. 15G.  As before, General License 15H continues to authorize certain activities ordinarily incident and necessary to the maintenance or wind down of operations or existing contracts involving GAZ or any other entity 50% or more owned by GAZ.  In addition, OFAC added a new authorization for the installation of occupant safety systems (including steering wheels, airbags, and seat belts) consistent with applicable automotive safety regulatory requirements in vehicles produced by GAZ or any entity it owns 50% or more. GL 15H is also now set to expire on July 22, 2020, instead of March 31.

Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.


Meg's practice involves assisting multinational companies with export compliance related matters, specifically trade sanctions and export control classifications. Additionally, she assists companies with respect to customs laws, anti-boycott laws and other trade regulation issues in the US and abroad. She also helps obtain authorizations from the US government for activities subject to sanctions regulations and US export control regulations, including the Export Administration Regulations and the International Traffic in Arms Regulations. Meg's practice extends to assistance in internal compliance reviews as well as enforcement actions and disclosures necessitated by US government action.