General Note on General Licenses for Transactions Related to Telecommunications and Mail (System Ed. Note)

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TURBOFAC Commentary (3813 words)

General Note on General Licenses for Transactions Related to Telecommunications and Mail

The typical IEEPA-based embargo program contains a general license authorizing transactions related to telecommunications and mail. See 510.516 (NKSR), 515.542 (CACR), 542.519 (SySR), 560.508 (ITSR), Ukraine GL Number 8 (Crimea) and Ukraine GL Number 19 (DNR/LNR). In addition, the GTSR contain a mail-related GL (594.509), and Venezuela General License 24 authorizes mail and telecommunications-related transactions involving the blocked Government of Venezuela. See also Russia-related General License 25 (telecommunications only).

While there are differences between these GLs at the margins, they share common characteristics, as discussed below. The commentary associated with the individual...