Case No. SY-177

Date issued: Mar. 16 2010

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TURBOFAC Commentary (101 words)

Notes:

This guidance letter was issued prior to the Government of Syria becoming blocked (542.201) and prior to the imposition of the prohibition on the exportation of services to Syria (542.207). This guidance letter interprets the generally irrelevant TLGSR, to which Syria remains subject as of 10/26/2021. Of some note, OFAC appears to construe the term “donation to a United States person” to include donations “through” United States person that is destined for a third-country person (i.e. cases where the U.S. person would not ordinarily be regarded as the donee) (596.504(a)(1)).