Russia-related General License 19 -  Authorizing Transactions Related to Personal Maintenance of U.S. Individuals Located in the Russian Federation Prohibited by Executive Order of March 11, 2022 (March 11, 2022)

Date issued: Mar. 11 2022

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TURBOFAC Commentary (164 words)

Notes:

1) Compare other "personal maintenance" GLs at, e.g., Venezuela General License 32 and 560.552. There has been scant guidance offered to interpret any version of this GL. Note that the GL authorizes transactions "transactions prohibited by section 1(a)(iv) of" EO 14068. Where transactions ordinarily incident to travel to Russia are not within the scope of this GL, such transactions are exempt from regulation altogether, even if they implicate other IEEPA-based sanctions prohibitions. Refer generally to General Note on the Applicability of IEEPA/TWEA Exemptions in EOs and Sanctions Regulations turbofac not Specifically Mentioning Them and Notable Examples Illustrating the Scope of the Travel Exemption.

2) Note: this GL covers "payment of taxes or fees," but it doesn't...