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The Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) has announced its extension of two general licenses related to GAZ Group, <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/ukraine_gl13n.pdf" target="_blank" rel="noopener noreferrer">Ukraine-related General License No. 13N</a>, &ldquo;Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group&rdquo; and <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/ukraine_gl15h.pdf" target="_blank" rel="noopener noreferrer">Ukraine-related General License No. 15H</a>, &ldquo;Authorizing Certain Activities Necessary to Maintenance or Wind Down of Operations or Existing Contracts with GAZ Group, and Certain Automotive Safety and Environmental Activities.&rdquo; In addition to extending the expiration dates to July 22, 2020, General License 15H expands the scope of authorized transactions and activities involving GAZ Group.
Effective March 20, 2020, General License 13N supersedes and replaces General License 13M. General License 13N authorizes all transactions and activities otherwise prohibited by Ukraine Related Sanctions Regulations, 31 C.F.R. &sect;&sect; 589.101-.901 (URSR), that are ordinarily incident and necessary to:
<ul>
<li>Divest or transfer debt, equity or other holdings in GAZ Group or in entities in which GAZ Group owns, directly or indirectly, a 50% or greater interests, to a non-U.S. person; or</li>
<li>Facilitate the transfer of debt, equity or other holdings in GAZ Group or in entities in which GAZ Group owns, directly or indirectly, a 50% or greater interests, by a non-U.S. person to another non-U.S. person.</li>
</ul>
Additionally, General License 13N requires that on or before August 5, 2020, all U.S. persons participating in transactions authorized by this general license file a comprehensive, detailed report with OFAC. The report should include the names and addresses of the parties involved, the type and scope of activities conducted, and the dates on which the activities occurred.
Similarly, effective March 20, 2020, General License 15H supersedes and replaces General License 15G. General License 15H authorizes all transactions and activities otherwise prohibited by the URSR that are ordinarily incident and necessary to:
<ul>
<li>The maintenance or wind down of operations, contracts, or other agreements, including the importation of goods, services, or technology into the United States, involving GAZ Group or any other 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;</li>
<li>Research and development regarding, and the related purchase, manufacture, and installation of, Electronic Stability Program systems and other advanced driver-assistance systems, or components thereof, consistent with applicable automotive safety regulatory requirements, in vehicles produced by GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest;</li>
<li>Research and development regarding, and the related purchase, manufacture, and installation of, components necessary to implement Euro 5/6 emissions standards in vehicles produced by GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest; or</li>
<li>The installation of occupant safety systems (including steering wheels, airbags, and seat belts) consistent with applicable automotive safety regulatory requirements in vehicles produced by GAZ Group or any other entity in which GAZ Group owns, directly or indirectly, a 50 percent or greater interest.</li>
</ul>
Previously, General License 15G was expanded to authorize transactions involving GAZ Group relating to research and development of Electronic Stability Program systems and other advanced driver-assistance system, and Euro 5/6 emissions standards. General License 15H further expands the scope of authorized transactions involving GAZ Group relating to the installation of occupant safety systems consistent with automotive safety regulation requirements.
General License 15H also requires that on or before August 5, 2020, all U.S. persons participating in transactions authorized by this general license file a comprehensive, detailed report with OFAC. The report should include the names and addresses of the parties involved, the type and scope of activities conducted, and the dates on which the activities occurred.
General Licenses 13N and 15H expire on July 22, 2020 at 12:01 a.m. EST.

OFAC Issues Amended Ukraine-Related General Licenses Involving GAZ Group