Russia-related General License 5 (February 24, 2022)

Date issued: Feb. 24 2022

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TURBOFAC Commentary (214 words)

Notes:

1) This is a fairly standard "international organizations" GL, except that, unlike similar GLs, it only includes entities that are not already covered by the exemption in EO 14024 for "transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, and contractors thereof)." "International Centre for Settlement of Investment Disputes (ICSID) and Multilateral Investment Guarantee Agency (MIGA) are not specialized agencies in accordance with Articles 57 and 63 of the Charter, but are part of the World Bank Group," which is a "specialized agency". See https://www.un.org/en/pdfs/un_system_chart.pdf (https://archive.md/wip/Uz33k).

2) By its terms, the GL is not limited to activities in which a U.S. person is a party to an underlying transaction. This...