PRINT
Case No. SY-2020-367174-1
Giovanna M. Cinelli, Esq.
Morgan, Lewis & Bockius LLP
1111 Pennsylvania Avenue, NW
Washington, DC 20004
Dear Ms. Cinelli:
This is in response to the request dated May 8, 2020 (the “Application”), on behalf of Premise Data Corporation (Corporation), to the Office of Foreign Assets Control (OFAC) for authorization for the Corporation, a San Francisco-based company that operates a crowdsource data collection platform. [***]
As you know, the Syrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR) block all property and interests in property that are in or come within the United States, or that are in or come within the possession or control of any U.S. person, including any foreign branch, of the Government of Syria and of certain other persons. SySR, § 542.201. Also, except as otherwise authorized, section 542.206 of...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) Notwithstanding the substantial redactions, there are a few significant statements in the guidance letter. First, OFAC provides the clearest statement we have concerning the relationship between the “official business” GL and subcontractors (“Please be advised that OFAC does consider subcontracts that are performed for the conduct of the official business of the Federal government by subcontractors to also be covered by this exemption and general license.”) See section 5 of General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof.
2) Section 501.801 of the RPPR sets out information OFAC expects in connection with specific license applications. (“(The applicant must supply all information specified by relevant instructions…or forms, and must fully disclose...