General License 12 - Authorizing Transactions Related to Certain Blocked Aircraft (November 4, 2025)

Date issued: Nov. 04 2025

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TURBOFAC Commentary (142 words)

Notes:

1) This unusual GL authorizes otherwise prohibited transactions “related to” three aircraft that appear on the SDN List, two of which were added for being “property in which Lukashenka, a person whose property and interests in property are blocked pursuant to E.O. 14038, has an interest,” and one of which was blocked for being “property in which” a potash company “Foreign Limited Liability Company Slavkali” has an interest.

* See https://home.treasury.gov/news/press-releases/jy1365, https://home.treasury.gov/news/press-releases/jy2533 and https://home.treasury.gov/news/press-releases/jy0512.

2) Query: when a license authorizes transactions “related to” property (e.g. aircraft and vessels) in which a blocked person has an interest, is it implicit in the license that the authorization covers transactions involving the “persons” associated with the blocked property? The interpretive “Note to paragraph (a)”...