ICC-related General License 4 - Authorizing Emergency Medical Services (June 05, 2025)

Date issued: Jun. 05 2025

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TURBOFAC Commentary (374 words)

Notes Common to Most “Emergency Medical Services” GLs

1) With the exception of the ITSR, FNKSR and FTOSR, all sanctions programs involving the blocking of persons have a general license either for the provision of emergency medical services, or otherwise for the provision of emergency medical services with the proviso that payments must be specifically licensed. In 2018, OFAC amended the Congo version of the provision to authorize both payments and the provision of the services, and all of the other six programs generally licensing both services and payments are the provisions most recently issued and/or amended. This suggests that, for all programs in which payments need to be specifically licensed, licenses for payments would be granted as...