Protecting American Intellectual Property Act of 2022 (PAIPA) General License 1, "Transactions Authorized Pursuant to the Cyber-Related Sanctions Regulations"

Date issued: Oct. 19 2026

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TURBOFAC Commentary (224 words)

Notes:

1) The Protecting American Intellectual Property Act of 2022 is a statute that is not incorporated into regulations (as of the date of issuance). This GL, which was issued in connection with the second designation pursuant to the PAIPA, operates somewhat like Cuba General License 1, except that in this case the relationship between the PAIPA and the Cyber-related sanctions regulations is not as strong as the Cuba sanctions programs as issue in Cuba General License 1. The apparent purpose of the GL is to ensure that persons blocked pursuant to PAIPA benefit from the standard OFAC GLs that apply to persons blocked to ordinary blocking authorities that are incorporated into regulations.

2) Query: would the provision of legal services to a person blocked solely pursuant to PAIPA be authorized? Section 578.507 of the Cyber...