Case No. SY-2020-367174-1

Date issued: Jun. 18 2020

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TURBOFAC Commentary (347 words)

Notes:

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...