Russia-related General License 52 - Journalistic Activities and Establishment of News Bureaus (September 15, 2022)

Date issued: Sep. 15 2022

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.

TURBOFAC Commentary (321 words)

Notes:

1) Compare Ukraine General License Number 25 (Crimea/Donbass) and 560.519 (ITSR). This GL is aimed at achieving a similar result as those, but the scoping is much different, given the difference in the nature of the prohibitions of the relevant sanctions programs.

Here, OFAC allows otherwise prohibited "new investment," the use of banks blocked pursuant to EO 14024, as well as certain transactions prohibited by directives issued under EO 14024. Note that this is a rare GL that licenses against Directive 4 Under EO 14024 (except with respect to debits to restricted accounts) as well as Directive 2 Under EO 14024 (processing of transactions only).

2) MERELY HIRING RUSSIANS ISN'T "NEW INVESTMENT"

As noted above, the scoping of the authorization section of this GL...