Russia-related General License 6C - Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials (January 17, 2023) [PDF contains all versions]

Date issued: Jan. 17 2023

Last substantive commentary amendment:
Feb. 02 2024

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TURBOFAC Commentary (866 words)

Notes:

1) Compare Ukraine General License Number 18, and comments thereto. Ukraine General License Number 18 was issued days before this one, in connection with the embargo on certain breakaway areas in Ukraine.

The scope of the two GLs is identical as it relates to the products covered. The main difference is that, unlike virtually other ag/med GLs, this one is designated primarily to allow for the facilitation of transactions by otherwise blocked persons. In this case, OFAC has clarified that banks blocked pursuant to the EO process transactions where the underlying transaction is covered by the GL.

2) Also of note is that, unlike any other ag/med GL, this one covers products "to, from, or transiting the Russian Federation". If, for example, agricultural products transit the Russian...