GL 115 generally authorizes all transactions involving Gazprombank Joint Stock Company ("Gazprombank"), or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, related to civil nuclear energy. Civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects and operations initiated or under construction as of November 21, 2024: the extraction, production, refinement, conversion, enrichment, fabrication, transport, or purchase of uranium in any form; the production, generation, transmission, or exchange of nuclear power, fuel, or waste; and the operation of civil nuclear energy projects. However, GL 115 does not authorize, for instance, transactions involving Gazprombank related to the development of new civil nuclear energy power plants after November 21, 2024, or related to the Paks II nuclear power plant project, including Paks II. Nuclear Power Plant Private Limited Company (Paks II. Ltd.), or any successor project.
Non-U.S. persons generally do not risk exposure to U.S. sanctions for engaging in transactions with blocked persons, including transactions related to existing civil nuclear energy as described in GL 115, where those transactions would not require a specific license if engaged in by a U.S. person.