Democratic Republic of the Congo-related General License 2, "Authorizing Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, Software Updates, or Clinical Trials."

Date issued: Jul. 10 2026

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TURBOFAC Commentary (174 words)

Notes:

1) Compare Ethiopia General License Number 3 (similar general ag/med GL issued pursuant to a list-based sanctions program). The GL is generally standard as it relates to “the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices,” but apart from Western Balkans GL 3 it is the only GL in any sanctions program (as of the date of issuance) that covers “the prevention, diagnosis, or treatment of any disease or medical condition”. This GL (but not the Western Balkans GL) clarifies that this covers “all transactions ordinarily incident to the provision of medical care and the operation of medical clinics or facilities.” It is notable that OFAC interprets the term “ordinarily incident and necessary to…the prevention, diagnosis, or treatment of any disease or medical condition”...