One of the most challenging aspects of sanctions is that they can be implemented with immediate effect.
Even when general licenses (“GL”) are issued authorizing certain activity, they may not be issued at the same time as the sanctions themselves, may permit only a narrow scope of activity, or be available to only a small number of actors. Speed of action becomes a critical factor when responding. Even when a “wind-down” of specific activities is authorized under a GL, timeframes are often t...
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