Russia-related General License 25G - Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications

Date issued: Oct. 30 2024

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TURBOFAC Commentary (1344 words)

Notes:

[6-12-24 update : GL amended on 6-12-24 to (i) remove “software, hardware, or technology” from the scope of the paragraph (a) and add a new paragraph (c) specifying that the exportation of such items is authorized only insofar as it is or would be licensed by BIS, (ii) add services such as “video conferencing” and “e-gaming” to the illustrative list of authorized services (in that respect bringing it line with 560.540 of the ITSR and 542.511 of the SySR), (iii) add “Garantex Europe OU” to the list of carved out entities. Note that the revisions to the GL omit reference to the “cloud-based services in support of” authorized software and services,...