NEWS Alert

Department of Treasury Authorizes Certain Transactions in Ukraine General License No. 3

Pursuant to Executive Order 13662, the Secretary of Treasury identified specified persons operating in sectors of the Russian economy subject to sanction and implemented through Directives issued by the Office of Foreign Assets Control (OFAC) pursuant to its delegated authorities.

Directive1, issued on July 16, 2014, prohibits transacting in, providing financing for, or otherwise dealing in debt with a maturity of longer than 90 days or equity if that debt or equity is issued on or after the sanctions effective date ("new debt" or "new equity") by, on behalf of, or for the benefit of the persons operating in Russia’s financial sector named under Directive 1, their property, or their interests in property. On September12, 2014, OFAC amended Directive 1, reducing the tenor of prohibited debt from longer than 90 days to longer than 30 days.

On October 6, 2014, the Department of the Treasury issuedGeneral License No. 3, Authorizing Transactions Involving Certain Entities Otherwise Prohibited by Directive 1 under Executive Order 13662. Specifically, General License No. 3 identifiesDenizBank A.S.

In other words, the United States exempted DenizBank, a bank based in Turkey, from broader U.S. sanctions on the Russian financial industry, allowing the Turkish lender to continue accessing U.S. debt markets despite its Russian ownership.

According to Reuters,DenizBank is owned by Sberbank, Russia's largest bank by assets, which became subject to U.S. sanctions in September, as described above.

Firms engaged in business in Russia must closely monitor these developments and address any compliance risks and requirements under EU law and corresponding TWG has been continuously representing and working with companies doing business in Russia, Ukraine and the CIS for two decades. For further information, please contact Mr. Glenn Wicks or Mr. Ronce Almond via email or via telephone at (202) 457-7790.

The Wicks Group - 601 Pennsylvania Avenue, NW, South Building, Suite 900, Washington, DC 20004 - T: +1.202.457.7790 /