Russia-related General License 105 - Authorizing Limited Safety and Environmental Transactions and the Unloading of Cargo Involving Certain Blocked Persons or Vessels (August 23, 2024)

Date issued: Aug. 23 2024

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TURBOFAC Commentary (133 words)

Notes:

1) Compare Russia-related General License 107, which is a standard “Authorizing Limited Safety and Environmental Transactions Involving Certain Blocked Persons or Vessels” GL. This is, as of the date of issuance, a unique GL insofar as it combines the standard “Limited Safety and Environmental Transactions” authorization with an unusual “Unloading of Cargo” GL. The typical “Limited Safety and Environmental Transactions” GL has a carveout specifying that “the offloading of” product presumed to be onboard the vessels is not covered by the GL. Here, that carveout is omitted, and there is an authorization for “all transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the delivery and offloading of cargo involving the blocked persons identified in paragraph (a)…provided that the cargo was loaded prior to August 23, 2024.”