The scope of such general licenses make it clear that banks and other counterparties are free to transact with the ABC Group and its subsidiaries as neither ABC nor any of its subsidiaries is subject to asset freezes as a result of developments in Libya.
The terms of the UK’s HM Treasury General License should permit transactions with ABC and each of its subsidiaries to the extent that any such transactions would otherwise have been restricted by The Libyan (Financial Sanctions) Order 2011 and, to the extent it applies, Council Regulation (EU) No 204/2011.
Similarly, the ABC Group falls within the scope of General Licence No. 1A issued by the US Treasury (which replaced General Licence No. 1). General Licence No. 1A permits US persons to continue to transact with the ABC Group, notwithstanding the assets freeze that was imposed on various Libyan and Libyan related persons by the previous Executive Order (No. 13566).
The Central Bank of Libya owns 59.3% of ABC and the Kuwait Investment Authority has a 29.6% stake in the bank.
ABC, which was established under the laws of the Kingdom of Bahrain, is regulated as a wholesale conventional bank by the Central Bank of Bahrain and its shares are listed on the Bahrain Bourse.