GL-116

Summary

This general license authorizes all transactions otherwise prohibited by E.O. 14024 that involve entities blocked solely because of a property interest of Bidzina Ivanishvili, or entities in which Ivanishvili holds a 50 percent or greater interest (directly or indirectly), so long as those entities are not on OFAC's SDN List. The authorization is subject to several carve-outs, including transactions prohibited by Directives 2 and 4 under E.O. 14024, transactions related to a specific Singapore Court of Appeal case, and transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations (RuHSR) involving persons blocked under the RuHSR beyond those described in paragraph (a).

Authorized activities

• All transactions prohibited by E.O. 14024 involving entities blocked solely due to a property interest of Bidzina Ivanishvili
• All transactions prohibited by E.O. 14024 involving entities in which Ivanishvili owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest
• Provided the entity is not on OFAC's SDN List

Conditions

The license does not authorize: (1) transactions prohibited by Directive 2 under E.O. 14024 (correspondent or payable-through accounts); (2) transactions prohibited by Directive 4 under E.O. 14024 (Central Bank of Russia, National Wealth Fund, and Ministry of Finance of Russia); (3) transactions related to the Singapore Court of Appeal Case, Credit Suisse Trust Ltd v. Ivanishvili, Bidzina and others [2024] SGCA(I) 5 and Civil Appeal No. 10 of 2023, and related proceedings, judgments, or payments, unless separately authorized; (4) any transactions otherwise prohibited by the RuHSR involving persons blocked under the RuHSR other than those described in paragraph (a), unless separately authorized. The authorized entities must not be identified on OFAC's SDN List.