Russia-related General License 13k - Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024

Date issued: Sep. 30 2024

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TURBOFAC Commentary (523 words)

Notes:

1) GL authorizes transactions subject to the broad prohibitions of Directive 4 Under EO 14024 involving “day-to-day operations in the Russian Federation”. This term is subject to interpretation, but not novel. Compare Venezuela General License 35 and 597.508.

2.1.1) GL amended on 5-25 2022 to (i) extend the expiration date to September 30, 2022, and to (ii) expand the scope of the authorization to "U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person". This is not to suggest that Directive 4 applies to non-U.S. persons that are "owned or controlled, directly or indirectly, by a U.S. person," but (presumably) to ensure that U.S. entities can be involved in ancillary transactions not otherwise prohibited by the law but nevertheless described by the GL....