061117-FACRL-SU-01 - Prohibitions Imposed by Executive Order 13412; Transshipments of Goods and Financial Transactions Conducted Through Certain Areas of Sudan

Date issued: Nov. 17 2006

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TURBOFAC Commentary (378 words)

Notes:

1) See comment to FAQ 490 re: the removal of the Sudanese Sanctions Regulations, along with it the repeal of 538.540, and the transfer of the Sudan TSRA provisions to 596.506.

[12-14-2020 UPDATE - 596.506 appears to be obsolete, following the Dec. 14, 2020 removal of Sudan from the State Sponsors of Terrorism list. See comments to 596.506.]

2) As it relates to the boilerplate "ordinarily incident" interpretive provision, it is only transactions that are otherwise prohibited by the pertinent part of the CFR that are authorized as a result of that provision. Confusion arises, however, out of the fact that some "exempt" transactions do benefit from automatic authorization of "ordinarily incident" transactions, while others don’t. It depends on why the transaction is exempt.

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