Ukraine General License Number 23 - Certain Transactions in Support of Nongovernmental Organizations’ Activities (March 11, 2022)

Date issued: Mar. 11 2022

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TURBOFAC Commentary (167 words)

Notes:

1) For comments on the aspects of NGO-related GLs such as this that are conducive to cross-programmatic comment, refer to General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note). Virtually all aspects of this GL are found in other similar GLs (see e.g. the nearly identical Ethiopia General License Number 2).

2) The exclusion for dealings involving blocked persons is unusual, but as of the date of issuance there are no persons blocked pursuant to EO 14065.

3) Note that this GL does not authorize transactions involving persons blocked pursuant to EO 13660 (or any other EO). This includes the "DONETSK PEOPLE'S REPUBLIC" and "LUHANSK PEOPLE'S REPUBLIC". It is unclear how, in practice, these (and other) designations...