Russia-related General License 27 - Certain Transactions in Support of Nongovernmental Organizations’ Activities (April 19, 2022)

Date issued: Apr. 19 2022

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TURBOFAC Commentary (171 words)

Notes:

1) For comments on the aspects of NGO-related GLs such as this that are conducive to cross-programmatic comment, refer to General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note). Virtually all aspects of this GL are found in other similar GLs (see e.g. the nearly identical Ethiopia General License Number 2).

2) The main differences between this and the typical NGO-related GL are (i) that it authorizes activities in two different countries, and (ii) that it has an exclusion for blocked persons with the exception of financial institutions. Note that, due to the carveout for all transactions otherwise prohibited by Directive 2 Under EO 14024, transactions involving Sberbank are excluded from the GL insofar as they also involve...