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1025. Executive Order (E.O.) 14068, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression” prohibits the importation into the United States of fish, seafood, and preparations thereof of Russian Federation origin. How does this affect Russia-related General License (GL) 6C?
Russia-related GL 6C (“Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials”) remains valid and authorizes, among other things, certain transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, ordinarily incident and necessary to (1) the production, manufacturing, sale, transport, or provision of agricultural commodities, including products such as fish, seafood, or preparations thereof — to the extent they fall within the definition of agricultural commodities provided in GL 6C — to, from, or transiting the Russian Federation (see FAQ 979). ...
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* FAQ amended on 2-23-24 to update references to GL 6C (from GL 6), and to add the last paragraph. The substance of that final paragraph simply affirms that GL 6C does not license against the import prohibitions of EO 14068. The comments below have not yet been amended to reflect the 2-23-24 changes.
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1) "Fish, seafood, and preparations thereof" are subject to the import ban in EO 14068, while Russia-related General License 6 authorizes "all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to: [] the exportation or reexportation of agricultural commodities…to, from, or transiting the Russian Federation…”
First note that EO 14024 and EO 14068 are separate authorities, and Russia-related General License 6 does not authorize any transaction otherwise prohibited by EO...