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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 25C
Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications
(a) Except as provided in paragraph (c) of this general license, all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), are authorized.
(b) Except as provided in paragraph (c) of this general license, the exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons, wherever located, to the Russian Federation of services, software, hardware, or technology incident to the exchange of communications over the internet, such as instant messaging, videoconferencing, chat and email, social...
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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...