General Note on Remittances; Guidance Letters Concerning Personal Remittances (System Ed. Note)

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TURBOFAC Commentary (1516 words)

General Note on Remittances; Guidance Letters Concerning Personal Remittances (System Ed. Note)

1) All six embargo programs active as of 2/2022 contain general licenses for noncommercial, personal remittances. The remittance architecture of the CACR is unique, but the four IEEPA-based programs (ITSR, FNKSR, SySR and the Crimea embargo) all contain similarly worded remittance GLs, permitting remittances by or for the benefit of non-blocked persons. (510.511 (NKSR), 542.512 (SySR), 560.550 (ITSR), Ukraine GL 6 (Crimea embargo) and Ukraine GL Number 21). The ITSR is different from the others insofar funds transfers are conditioned on the...