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582. I am located outside of the United States and seek to export goods from a third-country location in connection with activity for the maintenance or wind down of contracts or agreements with an entity listed on General License 12B (or any other entity in which a listed entity in 12B owns, directly or indirectly, a 50 percent or greater interest). Are such exports excluded from the authorization in General License 12B or otherwise subject to section 10 of SSIDES, as amended by section 228 of CAATSA, or section 5 of UFSA, as amended by section 226 of CAATSA?

Answer

No. Although General License 12B​ does not authorize the exportation of goods from the United States, paragraph (d)(4) of General License 12B does not similarly apply to the exportation of goods from a third country to another location.

Date Released
May 1, 2018