Case No. MUL-2013-300769-1

Date issued: Jun. 25 2014

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TURBOFAC Commentary (212 words)

Notes:

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 The "official business" portion of the letter, dealing with the now-repealed Sudanese Sanctions Regulations, is consistent with and similar to Case No. SU-2015-315714-1, which also relates to payments in connection with UN-related work.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,...