OFAC Publication of Ukraine-/Russia-Related General Licenses 13Q and 13R (GAZ Group Wind-Down)

Mechanism

The May 2022 Federal Register publication is an administrative codification of two consecutive, expired general licenses relating to GAZ Group (Gorkovsky Avtomobilny Zavod), Russia's second-largest commercial vehicle and truck manufacturer. The publication creates an official FR record for regulatory completeness but does not extend, revive, or modify either GL.

GL 13Q — GAZ Group divestiture wind-down (issued 24 Jan 2022; expired 27 Apr 2022): GL 13Q authorised all transactions and activities ordinarily incident and necessary either (i) to divest or transfer debt, equity, or other holdings in GAZ Group to a non-US person, or (ii) to facilitate the transfer of such holdings by a non-US person to another non-US person. GAZ Group had come under the Ukraine-/Russia-Related Sanctions program as part of the broader Deripaska sanctions complex; its holding structure included exposure to US and international investors that required an orderly divestiture window. GL 13Q provided a 90-day runway to exit positions before the wind-down window closed on 27 April 2022.

GL 13R — Continued wind-down authorisation (issued 25 Apr 2022; expired 25 May 2022): Issued two days before GL 13Q's expiration, GL 13R replaced and superseded GL 13Q. It authorised the same category of transactions — divesting or transferring GAZ Group debt, equity, or other holdings to a non-US person — for a further 30-day window ending 25 May 2022. This extension reflected the complexity of unwinding institutional holdings and allowed additional settlement time. OFAC required US persons participating in transactions under either GL to file a comprehensive report (counterparty names, transaction type, dates) within 10 business days after the respective expiration date.

Timing of FR publication: The Federal Register entry appeared on 27 May 2022 — two days after GL 13R itself expired. This sequencing mirrors OFAC's broader administrative practice of formally codifying web-published GLs in the FR after their operative window has closed.

Downstream implications

• Both GLs relate exclusively to GAZ Group; no other entity or sector is within scope.
• The FR codification has no operative sanctions effect: any transactions that were not wound down

within the GL windows became prohibited once GL 13R expired on 25 May 2022.

• The filing is contemporaneous with the post-February 2022 Russia sanctions escalation

architecture (EO 14024, new sectoral directives) but addresses a distinct, pre-invasion Deripaska-complex exposure rather than the post-invasion perimeter.

• US persons who held or facilitated GAZ Group positions after 25 May 2022 without authorisation

would face potential OFAC enforcement exposure.

Open questions

• Whether GAZ Group was subsequently re-designated or further restricted under EO 14024's expanded

blocking perimeter following Russia's February 2022 invasion.

• Whether OFAC extended any additional wind-down authorisations for GAZ Group beyond GL 13R, or

whether residual holders sought and obtained specific licences.