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Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Ukraine-/Russia-related General License 14 and publishing related FAQs. General License 14 authorizes U.S. persons to engage in specified transactions related to winding down or maintaining business with United Company RUSAL PLC (RUSAL) and its subsidiaries until October 23, 2018. The FAQs include a clarification that, in accordance with preexisting OFAC guidance, OFAC will not impose sanctions on foreign persons for engaging in the same activity involving RUSAL or its subsidiaries that General License 14 authorizes U.S. persons to engage in. OFAC is also issuing Ukraine-/Russia-related General License 12A, which replaces and supersedes General License 12 in its entirety.
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