031105-FACRL-BU-01 - Burmese Origin Imports - Burma

Date issued: Nov. 05 2003

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TURBOFAC Commentary (254 words)

General Note on interpretive Rulings Removed from OFAC’s Index: A substantial number of OFAC’s Interpretive Rulings—many of which serve as the only public statements that OFAC has ever made on certain fundamental interpretive questions with cross-programmatic implications—have been removed from OFAC’s website. With one rare exception, OFAC does not offer statements explaining why it has taken the rulings down, but in the vast majority of cases, the rulings were subsequently rendered either incorrect or confusing as a result of OFAC’s general licensing of conduct that would have been prohibited under the guidance. We include these rulings in the database because of the value they retain even after they have been taken down, but caution against reliance on them as our identification of the reasons why they were removed are necessarily speculative.

Notes:

1) This Guidance, which interpreted what was at the time a...