On April 17, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued General License 44A (“GL 44A”), authorizing the wind down by 12:01 am EDT on May 31, 2024 of transactions that were previously authorized under GL 44. OFAC also amended a consolidated frequently asked questions (“FAQs”) guidance document (“Updated Guidance”) to reflect the reissued General License 44A. Our previous blog post on the original issuance of GL 44 can…
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