Russia-related General License 42 - Authorizing Certain Transactions with the Federal Security Service (June 28, 2022)

Date issued: Jun. 28 2022

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TURBOFAC Commentary (115 words)

Notes:

1) Compare Cyber General License (No. 1B), which is substantively identical in scope. This GL was designed to not disturb the status quo with respect to the FSB.

2) See FAQ 501, FAQ 502, FAQ 503 and FAQ 504, each dealing with specific elements of Cyber General License (No. 1B). FAQ # 504 is notable for its confirmation that the Berman Amendment exemption for travel applies to the Cyber-related Sanctions Regulations, even though it contains no "exempt transactions" provision. FAQ # 504 also confirms that the travel exemption applies to entities sanctioned pursuant to Sec. 224 of the CAATSA, as is the case with the Russian FSB. The travel exemption likewise applies to EO 14024.