Case No. SU-2798

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TURBOFAC Commentary (642 words)

Notes:

1) This guidance letter adds to the corpus of notable “official business”-related guidance letters described in General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof. Here, we have a “corporation” (MBN), which OFAC appears to regard as not qualifying as the “United States Government” notwithstanding that it “receives 100% of its funding from grants administered by the Broadcasting Board of Governors” (the BBG was a U.S. government agency. See https://en.wikipedia.org/wiki/U.S._Agency_for_Global_Media).

However, the fact that MBN “receives 100% of its funding from grants administered by” a government agency appears to lead OFAC to conclude that, on a per se basis, i.e. without the need to examine the connection between the grant and activities at issue, the otherwise prohibited activities of MBN would qualify...

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Case No. SU-2798

TURBOFAC Commentary (642 words)