Case No. CU-2012-295570-1

Date issued: Aug. 21 2012

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TURBOFAC Commentary (787 words)

Consolidated comment on Case No. CU-2012-295570-1, License No. CU-80252-b and License No. CU-2012-293944-1 (all three in native PDF file).

Notes:

1) This is a rare example of a set of specific licenses that have no expiration date, of which the authorizations date, to some extent, back to 1979 (see p. 1 of License No. CU-80252-b).

2) Profess for Electronically Sending Funds to Sanctioned Country With No Direct Access to the U.S. Financial System

With respect to License No. CU-80252-b, the transactions authorized in that license would, today, likely all be authorized by the “official business” provision of 515.562(b), which did not exist in 2012. The license authorizes funds transfers by the Treasury Department and activities of Treasury’s “fiscal agent and the U.S. financial institution with which the fiscal agent has contracted” (i.e. contractors/subcontractors...