PEESA General License Number 1A - Authorizing Certain Activities Involving Federal State Budgetary Institution Marine Rescue Service (August 20, 2021)

Date issued: Aug. 20 2021

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TURBOFAC Commentary (645 words)

Notes:

1) Read in conjunction with FAQ # 894.

2) The phrase “related to the construction of the Nord Stream 2 pipeline project, the TurkStream pipeline project” may result in some tricky interpretive situations. “Related to” is always difficult to pin down, but it should be assumed that, at a minimum, that would include all activity that is within the scope of “sanctionable” conduct under PEESA.

3) This GL was amended on August 20, 2021, to account for the issuance of EO 14039 (Executive Order on Blocking Property with Respect to Certain Russian Energy Export Pipelines). Prior to August 20, 2021, the "Federal State Budgetary Institution Marine Rescue Service" (MRS) was a non-SDN, blocked pursuant to PEESA. See...