Russia-related General License 120 - Authorizing Limited Safety and Environmental Transactions and the Unloading of Cargo Involving Certain Persons or Vessels Blocked on January 10, 2025 (January 10, 2025)

Date issued: Jan. 10 2025

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (108 words)

Notes:

1) Compare Russia-related General License 105, which is the other GL that 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 January 10, 2025.”