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Case No. SY-2017-346136-1
[ ]
Red Rose CPS Ltd.
1B Peterborough Villas
London,
SW62AT
United Kingdom
Dear Mr. [ ]:
This responds to your request dated July 17, 2017, as supplemented on January 13, 2018, on behalf of Red Rose CPS Ltd. (the “Applicant”), a company located in the United Kingdom, to the Office of Foreign Assets Control (OFAC) (the “Application”), requesting authorization to work with U.S. nongovernmental organizations (NGOs) using your Red Rose program management system in Syria. In your Application, you state that your platform manages, distributes, and reports on the funds distributed through NGOs to support local communities through USAID projects.
Except as otherwise authorized, the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542, prohibit the exportation, reexportation, sale, or supply, directly or indirectly, from the United...
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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”...