Burma General License Number 2 - Official Activities of Certain International Organizations and Other International Entities (March 25, 2021)

Date issued: Mar. 25 2021

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TURBOFAC Commentary (168 words)


*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.