Russia-related General License 7A - Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services (May 5, 2022) [PDF includes all versions]

Date issued: May. 05 2022

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TURBOFAC Commentary (97 words)

Notes:

1) Compare Venezuela General License 33. This is a standard "overflight" GL, subject to very little interpretation by OFAC.

2) When the GL was initially issued, it licensed against EO 14024 (and directives issued thereunder). The GL was amended on 5-4-2022 to license against the entirety of the RuHSR. It is unclear what OFAC has in mind as a transaction incident to overflights, landings and air ambulance services that would require authorization under a different RuHSR authority. It is possible that the amendment was to account for the "new investment" prohibition of EO 14071.