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OFFICE OF FOREIGN ASSETS CONTROL
Global Terrorism Sanctions Regulations
31 CFR part 594
GENERAL LICENSE NO. 27
Authorizing Civil Aviation Safety and Wind Down Transactions Involving Fly Baghdad
(a) Except as provided in paragraph (c) of this general license, all transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), that are ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving Fly Baghdad are authorized through 12:01 a.m. eastern daylight time, March 22, 2024, provided that the goods, technology, or services that are provided, exported, or reexported are for use on aircraft operated solely for civil aviation purposes.
(b) Except as provided in paragraph (c) of this general license, all transactions prohibited by the GTSR that...
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1) Paragraph (b) is a standard wind-down general license, authorizing the processing of underlying transactions that may not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities. Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this. See in particular Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs.
2) Paragraph (a) temporarily authorizes "the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation" irrespective of whether the transactions wouldn't otherwise qualify as a wind down transaction (i.e. "new" contracts are authorized). The scope of paragraph (a) is not elaborated on, but see Third Amended Statement...