Notable OFAC Regulatory Provisions - 31 CFR § 537.305 - Exportation or reexportation of financial services to Burma (2005, Burma)

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TURBOFAC Commentary (328 words)

Notes:

1) While there are no similar examples in the current Part V of Chapter 31 of the , this repealed provision illustrates an application of 537.101 (a boilerplate 5XX.101 provision). 5XX.101 warns that terms may not carry the same definitions across sanctions programs. Here, a funds transfer to Burma was considered an export of "financial services," while in the case of, for example, the Sudanese Sanctions Regulations (See e.g. § 538.413 (2004)), funds transfers were explicitly interpreted as not constituting exports of financial services. In both cases, OFAC explicitly noted differing interpretations of similar language. (In the Federal Register notice introducing this provision (70 FR 48239), OFAC characterized 537.202 as a "explains the unique nature of" the term "exportation or reexportation of financial services to Burma" as meaning "any activity with a monetary aspect").

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31 CFR § 537.202; 537.305 - Exportation or reexportation of financial services to Burma (2005, Burma)

TURBOFAC Commentary (328 words)