EN+, Rusal and ESE were placed on the SDN List on April 6, 2018, 4 because they were owned and controlled by Oleg Deripaska either directly or indirectly. 5 Deripaska was designated as an SDN for his actions in support of senior Russian government officials and for operating in the Russian energy sector. 6 The sanctions imposed on Rusal were particularly impactful as Rusal is the world's second largest producer of aluminum. The price of aluminum soared in the weeks following Rusal's designation. To prevent disruption to the global aluminum market, OFAC provided temporary sanctions relief through general licenses that authorized continued dealings with the three companies. Upon their designation in April, the three companies petitioned OFAC to be removed from the SDN List. After eight months of negotiations, OFAC and the companies reached what the Notification Letter describes as a binding agreement specifying the terms of the companies' removal from the SDN List, referred to as the "Terms of Removal."