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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 19
Authorizing Transactions Related to Personal Maintenance of U.S. Individuals Located in the Russian Federation Prohibited by Executive Order of March 11, 2022
(a) Except as provided in paragraph (b) of this general license, individuals who are U.S. persons located in the Russian Federation are authorized to engage in 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 their personal maintenance within the Russian Federation, including payment of housing expenses, acquisition of goods or services for personal use, payment of taxes or fees, and purchase or receipt of permits, licenses, or public utility...
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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...