Ukraine General License Number 21 - Authorizing Noncommercial, Personal Remittances and the Operation of Accounts (February 21, 2022)

Date issued: Feb. 21 2022

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TURBOFAC Commentary (376 words)

Notes:

1) Compare the Crimea equivalents at Ukraine GL 6 (Noncommercial, Personal Remittances Authorized) and Ukraine GL 7 (Operation of Accounts Authorized).

2) On "operation of accounts", there are slight linguistic differences between the Crimea version and the EO 14065 version that do not appear to be substantive in nature. For example, this GL refers to the "maintaining, operating, or closing an account", instead of just the "operating", but "maintaining" and "closing" are presumably authorized in the Crimea GL as well (as ordinarily incident to the "operating" of the account). Also, this GL specifies that the accounts cannot be "for the benefit of an entity", but this appears to be implied in the Crimea version.

A substantive difference is that the "operation of accounts" GL is...