General Note on the Relationship Between Executive Orders, General Licenses and Sanctions Regulations Issued Pursuant to a Common National Emergency (System Ed. Note)

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (3166 words)

General Note on the Relationship Between Executive Orders, General Licenses and Sanctions Regulations Issued Pursuant to a Common National Emergency (System Ed. Note)

[Note: EO 13726 (Libya-related) was incorporated into the Libyan Sanctions Regulations, published on 10/03/2022. The below has not yet been amended to reflect this fact]

1) Background

5XX.101, the boilerplate provision titled “Relation of this part to other laws and regulations” provides as follows (using 591.101 of the Venezuela sanctions regulations to illustrate, with emphases added).

This part is separate from, and independent of, the other parts of this chapter, with the exception of part 501 of this chapter, the recordkeeping and reporting requirements and license application and other procedures of which apply to this part. Actions taken pursuant to part 501 of this chapter with respect to the prohibitions contained in this...