Case No. MUL-2015-320028-1

Date issued: Mar. 02 2018

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (877 words)

Notes:

1) Compare Case No. IA-2016-329758-1, Case No. IA-2016-329928-1, and more generally General Note on U.S. Person Employees Working for Non-U.S. Person Companies With Sanctions-Implicating Business (System Ed. Note). This request for guidance is by a non-U.S. person that has "U.S. person employees supporting BI Group’s sales of non-U.S. origin medicine, medical devices, and food to Cuba, Iran, Sudan, and Syria" (U.S. persons are not prohibited from working for non-U.S. persons that have sanctions-implicating business, but they cannot be involved in specific sanctions-implicating transactions of the non-U.S. employers).

2) Guidance letter is notable for the indication of specific licensing policy ("OFAC would consider specifically licensing activities of BI Group’s U.S. person employees on a case-by-case basis").

3) CACR PROFESSIONAL MEETINGS GL (TRAVEL FOR "PROFESSIONAL PURPOSES")...