Russia-related General License 101 - Authorizing Civil Aviation Safety and Wind Down Transactions Involving Certain Entities Blocked on August 9, 2024 (August 9, 2024)

Date issued: Aug. 09 2024

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TURBOFAC Commentary (243 words)

Notes:

1) Paragraph (b) is a standard wind-down general license, authorizing the processing of underlying transactions that may or 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...