1204. On December 27, 2024, OFAC designated Bidzina Ivanishvili (Ivanishvili) pursuant to Executive Order (E.O.) 14024. Can I continue to engage in transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's Specially Designation Nationals and Blocked Person List (SDN List) without facing sanctions risk?

Yes. Although transactions or other dealings involving Ivanishvili are generally prohibited as a result of OFAC's designation, OFAC concurrently issued General License (GL) 116 authorizing U.S. persons to engage in all transactions with any entity owned 50% or more by Ivanishvili provided that such entity is not identified on the SDN List. Non-U.S. persons may also engage in the transactions authorized by GL 116 without the risk of sanctions under E.O. 14024, as amended. However, U.S. persons are still prohibited from transacting with Ivanishvili himself unless exempt or otherwise authorized by OFAC. Additionally, as provided in paragraph (b), GL 116 does not authorize certain transactions, including transactions related to the Singapore Court of Appeal Case or related proceedings as specified in paragraph (b)(3) of the GL.