GL-119

Summary

General License No. 119 authorizes transactions otherwise prohibited by E.O. 14024 that are ordinarily incident and necessary to the official business of diplomatic or consular missions located outside of the Russian Federation, where those transactions involve Public Joint Stock Company Gazprom Neft or any entity in which Gazprom Neft holds a 50 percent or greater interest (directly or indirectly). The authorization is time-limited and subject to several carve-outs that exclude transactions prohibited by Directive 2 and Directive 4 under E.O. 14024, as well as other RuHSR-prohibited transactions not specifically covered by the license.

Authorized activities

• Transactions ordinarily incident and necessary to the official business of diplomatic or consular missions located outside of the Russian Federation involving Gazprom Neft
• Transactions involving any entity in which Gazprom Neft owns, directly or indirectly, a 50 percent or greater interest, that are ordinarily incident and necessary to the official business of such diplomatic or consular missions

Conditions

The license does not authorize: (1) transactions prohibited by Directive 2 under E.O. 14024 (Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions); (2) transactions prohibited by Directive 4 under E.O. 14024 (Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation); or (3) any transactions otherwise prohibited by the RuHSR, including transactions involving any blocked person under the RuHSR other than the blocked entities described in paragraph (a), unless separately authorized.