Case No. DFR-4-1

Date issued: Jun. 02 2014

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TURBOFAC Commentary (417 words)

Notes:

1) This letter was issued when there was still a comprehensive embargo on Sudan, with there being broad exemptions for the “Specified Areas of Sudan” within that embargo, in addition to a separate list-based blocking program codified in the “Darfur Sanctions Regulations”. For the Sudanese Sanctions Regulations (SSR) as they existed at the relevant time, see https://www.govinfo.gov/content/pkg/CFR-2014-title31-vol3/xml/CFR-2014-title31-vol3-part538.xml. As noted in the guidance letter, there was a prohibition (538.205) on exportation of services to Sudan (and consistent with OFAC’s practice in the IEEPA-based embargo context this was interpreted to cover all person in or “ordinarily resident” in Sudan see e.g. License No. MUL-2013-302171-1). There was also an exemption at 538.212(g) stating that, “the prohibitions contained in this part do not apply to activities or related transactions with respect to the Specified Areas of Sudan”. This exemption...