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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 18
Authorizing U.S. Dollar-Denominated Banknote Noncommercial, Personal Remittances Prohibited by Executive Order of March 11, 2022
(a)(1) Except as provided in paragraph (b) of this general license, all transactions prohibited by section (1)(a)(iv) of Executive Order of March 11, 2022, Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression, that are ordinarily incident and necessary to the transfer of U.S. dollar-denominated banknote noncommercial, personal remittances from: (i) the United States or a U.S. person, wherever located, to an individual located in the Russian Federation; or (ii) a U.S. person who is an individual located in the Russian Federation, are authorized.
Note to paragraph (a)(1). Noncommercial, personal remittances do not include...
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1) This is a highly unusual "noncommercial, personal remittances" GL insofar as it is the only on (active as of the date of issuance) that serves to lift limited prohibitions, rather than a broad service embargo or blocking prohibition. Otherwise, the scope of application would appear to mirror that of the typical remittance GL. Refer generally to General Note on Remittances; Guidance Letters Concerning Personal Remittances (guidance interpreting “noncommercial, personal remittances”).
2) The GL would appear to apply to, e.g. entities like Western Union, or other money exchangers that dispense USD banknotes to Russia. Refer to comments to EO 14068 for discussion of the scope of application of the banknote export ban.
3) See section 3(ii) of General Note on the Terms "Knowingly," "Should Have...