Russia-related General License 34 - Authorizing the Wind Down of Accounting, Trust and Corporate Formation, and Management Consulting Services (May 8, 2022)

Date issued: May. 08 2022

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TURBOFAC Commentary (102 words)

Notes:

1) Compare FAQ # 1038. See generally Examples of Transactions Deemed to Be, and Not to Be, Within the Scope of the Standard “Wind-Down” and “Maintenance” GLs, and note that the carveout in the EO 14071 services prohibition for "wind down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person" operates independent of this GL.

2) See General Note on E.O. 14071-Based Prohibitions on the Exportation of Certain Services to Persons Located in Russia (System Ed. Note) for comments on the relevant prohibitions in general.