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996. In light of the issuance of Afghanistan-related General License (GL) 20, are U.S. persons still required to abide by the narrower scope of Afghanistan-related GLs 14, 15, 16, 17, 18, and 19?
To the extent authorization is required, Afghanistan-related GL 20 authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).
Therefore, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related 14, 15, 16, 17, 18 and 19. Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, 16, 17, 18, and 19. As with all OFAC...
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1) FAQ confirms general principle that GLs issued in connection with the same sanctions program may overlap in scope.