589. Will foreign persons be subject to sanctions under the Section 5 of the Ukraine Freedom Support Act (UFSA) or Section 10 of the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act (SSIDES), as amended, respectively, by Sections 226 or Section 228 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) for engaging in activities with GAZ Group or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest?

As described in FAQs 542, 545, 574, and 579, a transaction will not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by section 228 of CAATSA, and section 5 of UFSA, as amended by section 226 of CAATSA, if a U.S. person would not require a specific license from OFAC to participate in such a transaction.  Therefore, activity authorized by General License (GL) 15L, and occurring within the time period authorized by GL 15L, would not be considered “significant” for the purposes of a sanctions determination under section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA.

Date Updated: April 25, 2022