Russia-related General License 25C - Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications (July 14, 2022) [PDF contains all versions]

Date issued: Jul. 14 2022

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TURBOFAC Commentary (1051 words)

Notes:

1) This GL is a combination of two GLs that appear in all full embargo programs, and several less-than-full-embargo programs (e.g. the Venezuela program). Note that it licenses against the “new investment” Executive order incorporated into the RuHSR (EO 14071), but not EO 14066 or EO 14068. The GL was amended on 5-8-2022 to add the carveout for certain SDNs (Joint Stock Company Channel One Russia, Joint Stock Company NTV Broadcasting Company, or Television Station Russia-1), and further amended on 6-2-22 to add Limited Liability Company Algoritm to the carveout list.

2) TELECOMMUNICATIONS GL

The telecommunications GL (paragraph (a)) is similar in scope to those found in other programs, and the carveouts in paragraph (c) are unlikely to pose much...