Case No. SU-3568

Date issued: Oct. 21 2011

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TURBOFAC Commentary (187 words)

Notes:

1) As with Case No. SU-2014-311179-1, Case No. SU-2015-315714-1, Case No. SU-1917 and Case No. SU-3464, this guidance letter reflects OFAC’s longstanding interpretation of the standard “official business” authorization language as accommodating a U.S. person providing services (or otherwise exporting goods) to a third-country private contractor of the UN, where the U.S. person selling the goods is not an actual direct “contractor” of the UN. Here. the U.S. person would be exporting “goods” to “eight stores in Sudan operated by Supreme Foodservice GmbH,” where Supreme Foodservice GmbH was the entity that had the UN contract; not the U.S. person. OFAC determines that this is “authorized by the SSR and would not require a specific OFAC license” under the GL for “transactions for the conduct of the official business...