590. I am a foreign person that seeks to pay GAZ Group or another entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest for goods or services connected with activities authorized by General License (GL) 15L.  Am I required to deposit payment into a blocked account at a U.S. financial institution in order for my payment not to be considered “significant” for purposes of section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA?

No.  U.S. persons may engage in activities authorized by GL 15L that occur on or after May 22, 2018, except for activities involving blocked persons other than GAZ Group (or any entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest) without making associated payments into a blocked account.  Similarly, foreign persons may engage in activities that would be authorized by GL 15L if engaged in by a U.S. person without making associated payments into a blocked account.

Date Updated: April 25, 2022