ICC-related General License 7 - Official Business of the United States Government (June 05, 2025)

Date issued: Jun. 05 2025

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TURBOFAC Commentary (246 words)

Notes:

[Update - Implemented at 528.509 on 7-1-25. The 528.201 version of this provision makes more sense than ICC-related General License 7 because it authorizes transactions prohibited by EO 14203 (already exempt) plus transactions prohibited by yet-to-be-issued EOs related to EO 14203]

1) This is an ordinary "Official business of the [Federal/United States] Government" GL. For detailed commentary on the scope and operation of the “official business” exemptions and GLs, see General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof.

2) This appears to be the first instance in which OFAC has issued a GL to authorize transactions that are, by OFAC's own admission in the note to the GL, already fully exempt...