GL 15L superseded GL 15K on April 25, 2022. While GL 15K authorized certain transactions and activities that were ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and that were in effect prior to April 6, 2018, GL 15L only authorizes certain transactions and activities that are ordinarily incident and necessary to the wind down of transactions involving GAZ Group and any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. eastern daylight time, May 25, 2022.
All funds blocked prior to 12:01 a.m. eastern daylight time, May 22, 2018, remain blocked. Unlike its predecessors, this general license no longer authorizes the use of these blocked funds for the activities it authorizes. In addition, U.S. persons have not been required to block transactions authorized by GL 15L or its predecessors that occurred on or after May 22, 2018; however, transactions involving blocked persons other than GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, must be blocked. For information regarding the relationship between GL 15L and foreign persons, please see FAQs 589 and 590.
After the expiration of GL 15L, unless exempt or authorized by OFAC, U.S. persons will be prohibited from engaging in transactions involving GAZ Group, or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest, and must block property or interests in property of such persons that are in, or come within, the United States, or the possession or control of a U.S. person.
Date Updated: April 25, 2022