Ukraine General License Number 18 - Authorizing the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates to Certain Regions of Ukraine and Transactions Related to the Coronavirus Disease 2019 (COVID-19) Pandemic (February 21, 2022)

Date issued: Feb. 21 2022

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TURBOFAC Commentary (3441 words)

Notes:

1) As of the date on which it was issued, Ukraine General License Number 18 is the broadest ag/med GL that appears in any embargo program. Similar to other ag/med GLs issued since the start of the Biden Administration, the GL is not "dual tracked," i.e. it does not have a list of "excluded" items that are otherwise within the TSRA-derived definitions of "agricultural commodity," "medicine" and "medical device". Compare, e.g., Ethiopia General License Number 3, which is substantively identical to this GL except insofar as this GL includes the authorization specific to exportations for "the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19) in the Covered Regions".

Other features that make this GL broader than the typical ag/med GL found in an embargo program, including Ukraine General License Number...