On 12th March 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three amended General Licenses (GL):
GL15C: Authorizing Transactions Involving Certain Banks for Certain Entities
GL16C: Authorizing Maintenance of U.S. Person Accounts and Noncommercial, Personal Remittances involving Certain Banks
GL36A: Authorizing Certain Activities Necessary to the Wind Down of Transactions Involving Rosneft Trading S.A. or TNK Trading International S.A
In conjunction with GL36A, OFAC has published two amended Frequently Asked Questions (FAQ 817 and 818), and added “TNK TRADING INTERNATIONAL S.A.” to the Specially Designated Nationals and Blocked Persons List (SDN List) and the Sectoral Sanctions Identifications List (SSI List).