Case No. SY-2017-346136-1

Date issued: Jul. 27 2018

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TURBOFAC Commentary (330 words)

Notes:

At the time this guidance letter was issued, https://www.govinfo.gov/content/pkg/CFR-2018-title31-vol3/xml/CFR-2018-title31-vol3-part542.xml#seqnum542.516 provided that “Nongovernmental organizations are authorized to export or reexport services to Syria that would otherwise be prohibited by § 542.207 in support of the following not-for-profit activities…[a]ctivities to support humanitarian projects to meet basic human needs in Syria, including, but not limited to, drought relief, assistance to refugees, internally displaced persons, and conflict victims, food and medicine distribution, and the provision of health services…”

Here, the applicant (Red Rose CPS Ltd) is a non-U.S. person entity that appears to work primarily with NGOs, but is not, itself, an NGO. It is a privately held company specializing in technology solutions for the humanitarian sector (see https://www.redrose.io/aboutUs.html).

The applicant seeks “authorization to work with U.S. nongovernmental organizations” through the use of its “platform”...