Ukraine General License Number 20 - Official Business of Certain International Organizations and Entities (February 21, 2022)

Date issued: Feb. 21 2022

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TURBOFAC Commentary (357 words)

Notes:

1) This is a fairly standard "international organizations" GL, as it appears in sanctions prohibitions issued by the Biden Administration. Note that, unlike similar GLs, it refers to "International Organizations and Other International Entities," as opposed to only the "United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations". Compare e.g., Venezuela General License 20; 510.514. Some of the non UN-Related organizations listed appear in other GLs, and some are specific to this GL. This is the only such GL that applies to the Organization for Security and Co-operation in Europe.

2) By its terms, the GL is not limited to activities in which a U.S. person is a party to an underlying transaction. This means that U.S. persons may engage in ancillary transactions that would...