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OFFICE OF FOREIGN ASSETS CONTROL
Executive Order 14014 of February 10, 2021
Blocking Property With Respect to the Situation in Burma
GENERAL LICENSE NO. 2
Official Activities of Certain International Organizations and Other International Entities
(a) Except as provided in paragraph (b) of this general license, all transactions and activities prohibited by Executive Order (E.O.) 14014 that are for the conduct of the official business of the following entities, by employees, grantees, or contractors thereof are authorized:
(1) The United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations;
(2) International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA);
(3) The African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, and...
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*6-1-2021 Update: This GL is valid as of 6-1-2021, notwithstanding that it was not implemented in the new Burma Sanctions Regulations.
1) This is a fairly standard "international organizations" GL, except that, unlike similar GLs it refers to "International Organizations and Other International Entities," as opposed to only the "United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations". Compare e.g., Venezuela General License 20; 510.514.
2) By its terms, the GL is not limited to activities in which a U.S. person is a party to an underlying transaction. This means that U.S. persons may engage in ancillary transactions that would be subject to the otherwise-applicable prohibitions, even if such activities pertain to a transaction involving no U.S. person.
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