Reed Smith Client Alerts

On Monday, April 23, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new general license that expands the ability of companies to wind down their affairs with United Company RUSAL PLC and its subsidiaries (collectively Rusal). Specifically, this new license authorizes all transactions and activities “ordinarily incident and necessary to the maintenance or wind down of operations, contracts, or other agreements, including the importation of goods, services, or technology into the United States, involving” Rusal that were in effect prior to April 6, 2018. Such transactions and activities must be completed by “12:01 a.m. eastern daylight time, October 23, 2018.”

Hand blocking dominoes
Rusal, one of the world’s largest aluminum producers, was sanctioned by OFAC and added to the Specially Designated National List (SDN List) on April 6 for its entanglement with Russian oligarch Oleg Deripaska. Rusal has petitioned OFAC for its removal from the SDN List and OFAC has signaled that such delisting would be possible if Oleg Deripaska divests his interest in Rusal.