Case No. MUL-2013-302171-1 [Application Included]

Date issued: Oct. 19 2015

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (764 words)

Notes:

1) LICENSING POLICY

The application (p. 7), guidance letter (p. 1) and license (p. 3), altogether, are most notable for their statements of licensing policy as it relates to certain educational activities by U.S. persons in third countries involving persons in or ordinarily resident in certain sanctioned countries. In the application, TAMU requests authorization (to the extent required) for activities involving Iran, Syria, and then-comprehensively embargoed Sudan. OFAC responds by citing 560.544 of the ITSR with respect to Iran, and determining that nothing beyond that would be specifically licensed. With respect to Syria and Sudan, OFAC issued a specific license to, in effect, put those destinations on equal footing with Iran (i.e. grant with respect to those countries that which is granted in the Iran context by 560.544).

2) THE COMBINED REQUEST FOR...