Case No. IA-2013-300305-1 [Application Included]

Date issued: Jul. 12 2013

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TURBOFAC Commentary (1132 words)

Notes:

1) As described in the application (see PDF), USAID (a U.S. person contacting OFAC at time when there was no “official business” GL to cover its activities) requested interpretive guidance from OFAC concerning its substantial involvement in the construction of an electricity transmission line that would run through several non-sanctioned countries, including Tajikistan. More specifically, USAID provided technical assistance concerning the design of the transmission line, and "is the sole source of funding for the" secretariat of the transmission line. USAID explained to OFAC (see p. 4, PDF) that one of the electricity generation facilities developed in Tajikistan was owned by an entity (Sangab) that “appears to have connection to the Iranian government” and that received a loan from the Export Development Bank of Iran, an SDN blocked pursuant to the