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OFFICE OF FOREIGN ASSETS CONTROL
Belarus Sanctions Regulations
31 CFR part 548
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 101
Authorizing Civil Aviation Safety and Wind Down Transactions Involving Certain Entities Blocked on August 9, 2024
(a) Except as provided in paragraph (c) of this general license, all transactions prohibited by the Belarus Sanctions Regulations, 31 CFR part 548 (BSR), and Executive Order (E.O.) 14024, that are ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving one or more of the following blocked entities (collectively, the “Blocked Entities”) are authorized through 12:01 a.m. eastern daylight time, September 10, 2024, provided that the goods, technology, or services that are provided, exported, or...
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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...