Case No. UKRAINE-EO13662-2018-355615-1

Date issued: Jun. 08 2020

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TURBOFAC Commentary (257 words)

Notes:

1) At the time the guidance letter was issued the URSR incorporated the prohibitions of EO 13662, but there was no “exempt transactions” prohibition. (https://www.govinfo.gov/content/pkg/CFR-2020-title31-vol3/xml/CFR-2020-title31-vol3-part589.xml). The applicant had, in a series of filings with the SEC from 2015-2020 (IHS INC., 2015, 2018. 2020 10-K Filings), disclosed that it was providing access to “ an online trade data system offering global merchandise trade statistics such as import and export data from official sources in more than 65 countries,” and doing so under the informational materials exemption. It is not exactly clear what the informational materials at issue are here, but the reference to “electronic access to the Informational Products” as the subject to the guidance letter involved some kind of web-based financial information product. What is notable about the...