On December 19, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 115 to generally authorize transactions involving Gazprombank that are related to civil nuclear energy. After sanctioning Gazprombank in November 2024 in order to further limit Russia’s access the international financial system (see Thompson Hine Update of November 22, 2024), OFAC has issued this general license to allow transactions with Gazprombank, or any entity in which Gazprombank owns, directly or indirectly, a 50 percent or greater interest, that are related to civil nuclear energy until June 30, 2025.
The term “related to civil nuclear energy” means transactions undertaken solely to maintain or support civil nuclear projects initiated before November 21, 2024. OFAC Russia FAQ 1203 further clarifies that “civil nuclear energy means the following activities when undertaken solely to maintain or support civil nuclear energy projects and operations initiated or under construction as of November 21, 2024: the extraction, production, refinement, conversion, enrichment, fabrication, transport, or purchase of uranium in any form; the production, generation, transmission, or exchange of nuclear power, fuel, or waste; and the operation of civil nuclear energy projects.” This GL 115 does not cover transactions related to the development of any new civil nuclear energy power plants after November 21, 2024, or transactions related to the Paks II nuclear power plant project, including Paks II. Nuclear Power Plant Private Limited Company (Paks II. Ltd.), or any successor project. Certain other transactions under this general licenses remain unauthorized and therefore requires close analysis.