31 CFR § 589.518 - Transactions necessary and ordinarily incident to publishing in the Crimea region of Ukraine.

Date issued: May. 02 2022

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TURBOFAC Commentary (1280 words)

Notes common to the Crimea, ITSR, SYSR and CACR Publishing GLs (see below for provision-specific comments):

The Crimea, ITSR, SySR and CACR GL for transactions necessary and ordinarily incident to publishing are, with some exceptions identified below, of virtually identical scope.

1) Except for the SySR version, this is one of the rare GLs that contain the qualifier "[t]o the extent that such activities are not exempt from this part;" in recognition of the fact that this GL owes its existence to a lawsuit alleging that OFAC’s restrictions on publishing activities amounted to regulation ultra vires of the IEEPA/TWEA Berman Amendment (as well as unconstitutional)....