Ukraine General License Number 24 - Transactions Related to the Provision of Maritime Services (March 18, 2022)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (133 words)

Notes:

1) This us unique to the DPR/LPR embargo imposed by 14065. It has no analogue in any other sanctions program, and was not supplemented with guidance when issued. The GL was evidently issued to account for a number of persons ordinarily resident in the "Covered Regions" serving as crew on commercial vessels.

2) Implicitly, the GL appears to serve as a rare interpretation of the "new investment" prohibition. It appears evident that the new hiring and paying of persons ordinarily resident in the Covered Regions would not constitute "new investment" in such regions. Were the GL limited to, for example, the retention of pre-existing employees resident in the Covered Regions, this is something one would have expected OFAC to make clear in the GL or an associated FAQ.

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Ukraine General License Number 24 - Transactions Related to the Provision of Maritime Services (March 18, 2022)

TURBOFAC Commentary (133 words)