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Case No. MUL-2013-300769-1
The Development Initiative Limited
Mercury House, 4th Floor
101 Front Street
Hamilton HM12
Bermuda
Attn: [ ], CA, Chief Financial Officer
Dear Mr. [ ]:
This responds to your request dated January 30, 2013 (the “Application”) to the Office of Foreign Assets Control (“OFAC”), requesting authorization to receive wire transfers from the United Nations for work related to clearing landmines that is conducted in the Republic of South Sudan, Darfur, and Somalia.
Except for certain exemptions and general authorizations, the Sudanese Sanctions Regulations (“SSR”), 31 C.F.R. Part 538, prohibit the exportation or reexportation, directly or indirectly, to Sudan of any goods, technology, or services from the United States or by a U.S. person, wherever located, or requiring the issuance of a license by a federal agency....
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1) The applicant is a non-U.S. person entity that "provides commercial and humanitarian landmine clearance, unexploded ordnance disposal, training and remote logistics solutions in inaccessible and often hostile locations, primarily across Africa and the Middle East." (https://www.linkedin.com/company/the-development-initiative-limited-tdi-/). The "official business" portion of the letter, dealing with the now-repealed Sudanese Sanctions Regulations, is consistent with and similar to Case No. SU-2015-315714-1, which also relates to payments in connection with UN-related work. In this case, however, the payments would be received directly from the UN, so they are more clearly authorized, whereas in Case No. SU-2015-315714-1 the transactions at issue were "financial transactions necessary for the payment of contract expenses under the United Nations Procurement Division (UNPD)." See generally General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees,...