Case No. FNK-2017-345492-1 (With Related State Dept. Communication)

Date issued: Jul. 10 2017

Last substantive commentary amendment:
Apr. 03 2026

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TURBOFAC Commentary (745 words)

Notes:

[2026-04-04 update - read in light of OFAC's 2026 Sham Transactions Guidance. The below has not yet been updated to reflect the issuance of the Sham Transactions Guidance].

1) The GL to which the letter refers is FNKSR - General License 3.

2) The letter is notable as confirmation that requests for general licenses can be made through the ordinary licensing process, just as requests for specific licenses can. OFAC's licensing division will review the application and reply. This is not otherwise evident from the licensing portal application instructions. In this case, OFAC notes that, as a non-U.S. person, the SDN can apply for a specific license (which, for practical purposes, would be a license that allows U.S. persons to be involved in transactions that also involve the SDN).

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