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OFFICE OF FOREIGN ASSETS CONTROL
Russian Harmful Foreign Activities Sanctions Regulations
31 CFR part 587
GENERAL LICENSE NO. 6D
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
(a) Except as provided in paragraph (c) of this general license, all transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, related to:
(1) the production, manufacturing, sale, transport, or provision of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or
(3) clinical trials and other medical research activities are authorized.
(b) For the purposes...
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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