Russia Sanctions: General Licenses, Deadlines, Russian Counter-Measures-- What's the Latest?

As the world turns... There have been several key developments recently in the Russia sanctions context:

• Issuance of General License 15.  This general license, issued May 22, authorizes maintenance and winding down of pre-April 6 business with GAZ Group and its subsidiaries through October 23.  The authorization is similar in scope to General License 14, issued on April 23 with respect to Rusal.
• Issuance of General License 13B.  This general license, issued May 31, added EN+ Group PLC to the list of companies (previously consisting of GAZ Group and Rusal) for which divestment of holdings is permitted, and extended the deadline for divestment from June 6 to August 5.  The general license also permits divestment of holdings in the subsidiaries of the covered companies under certain circumstances.
• Issuance of General License 16.  This general license, issued just yesterday, authorizes certain activities to maintain or wind down pre-April 6 business with EN+ Group PLC,  EuroSibEnergo, and their subsidiaries through October 23.
• Lapse of General License 12C.  This general license previously had authorized certain activities to maintain or wind down pre-April 6 business with several Russian companies (see the list below).  That authorization lapsed yesterday, meaning that business with the companies covered by the general license no longer is permitted.
• President Putin signs Russian "counter-sanctions" into law.  Yesterday, President Putin signed into law a bill that gives him the power to sever relations with "unfriendly" countries and prohibit trade with such countries.  Notably, the bill as initially proposed would have banned a range of US goods and services, including certain US food, alcohol, medicine, and consulting services, but it was watered down significantly before reaching the president's desk.  Consideration of a related bill, which would criminalize compliance with US sanctions on Russian soil, has been postponed for the time being.

So where do things stand?  Here's a short summary:

• Certain activity to maintain or wind down pre-April 6 business with Rusal, GAZ Group, EN+ Group PLC, EuroSibEnergo, and their subsidiaries is permitted through October 23.  Note that General Licenses 14, 15, and 16 may vary in scope, and each should be assessed carefully.
• Certain activity to divest holdings in Rusal, GAZ Group, EN+ Group, and (under certain circumstances) their subsidiaries is permitted through August 5.
• Business with AgroHolding Kuban, Basic Element Ltd., B-Finance Ltd., Gazprom Burenie, Ladoga Menedzhment, NPV Engineering, Renova Group, and Russian Machines is no longer authorized pursuant to any OFAC general license as of today, June 5.
• Business with Rosoboroneksport, Russian Financial Corporation, and all of the individuals designated for sanctions on April 6-- none of which were eligible for relief under the general licenses that OFAC has issued in recent weeks-- remains off-limits.
• President Putin has signed certain counter-measures into law, and more may follow with respect to compliance with US sanctions on Russian soil.