Russia-related General License 41 - Authorizing Certain Transactions Related to Agricultural Equipment (June 28, 2022)

Date issued: Jun. 28 2022

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TURBOFAC Commentary (89 words)

Notes:

1) Compare early versions of Ukraine General License Number 15, which at one point authorized virtually all otherwise prohibited transactions involving a blocked entity that were ordinarily incident to its manufacture of automobiles. This GL appears to be extremely broad, except insofar as the "blocked accounts" carveout serves to limit the practical scope of it to transactions involving outflows of cash by the blocked entities, rather than inflows.

2) This is a rare GL that licenses against Directive 2 Under EO 14024 and Directive 4 Under EO 14024.