Case No. MUL-2016-326574-1

Date issued: Jul. 17 2017

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TURBOFAC Commentary (281 words)

Notes:

1) The ICRC is a Swiss entity. Iran GL E provides that “nongovernmental organizations are authorized to export or reexport services to or related to Iran in support of [certain specified] not-for-profit activities that are designed to directly benefit the Iranian people.” 542.516 of the SySR, as it existed at the time, likewise stated that “[n]ongovernmental organizations are authorized to engage in the following transactions and activities.” The question is whether, where an NGO is not a U.S. person and therefore generally does not require OFAC authorization to engage in a given transaction, the NGO GL extends to “U.S. persons working as employees of or contractors for the [non-US NGO]” (will they be “authorized to provide humanitarian services in support of, or on behalf of” the non-US NGO. OFAC suggests that...