Russia-related General License 18 - Authorizing U.S. Dollar-Denominated Banknote Noncommercial, Personal Remittances Prohibited by Executive Order of March 11, 2022 (March 11, 2022)

Date issued: Mar. 11 2022

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TURBOFAC Commentary (244 words)

Notes:

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...