Ukraine General License Number 19 - Authorizing Transactions Related to Telecommunications and Mail (February 21, 2022)

Date issued: Feb. 21 2022

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TURBOFAC Commentary (370 words)

Notes:

1) For comments on this GL and others that are substantially similar, refer to General Note on General Licenses for Transactions Related to Telecommunications and Mail.

2) Compare Ukraine General License Number 8 (substantively similar GL for Crimea). Two differences to note: ones is that the Crimea GL refers to "all transactions with respect to the receipt and transmission of telecommunications involving the Crimea region of Ukraine," while this one refers to " all transactions prohibited by Executive Order (E.O.) of February 21, 2022 involving...the “Covered Regions”[] that are ordinarily incident and necessary to the receipt or transmission of telecommunications."

In this case, it is not necessary that the "telecommunications" themselves involve the Covered Regions, only that the transactions be "ordinarily incident and necessary to the receipt or transmission of...