Case No. SY-2019-358832-1 [Application Included]

Date issued: Dec. 09 2019

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TURBOFAC Commentary (201 words)

Notes:

1) A key portion of this letter is redacted, but based on the context of (i) OFAC and the applicant's references to 542.207 and 542.209, (ii) the Syrian Democratic Council being the client, and (iii) the applicant and OFAC's specific citation to the portion of the legal services GL that covers "legal advice and counseling on the requirements of and compliance with the laws of the United States or any jurisdiction within the United States, provided that such advice and counseling are not provided to facilitate transactions in violation of the SySR," it is highly likely that the legal advice at issue here involved sanctions advice pertaining to transactions involving to the sale of Syrian-origin petroleum controlled by the Syrian Democratic Council. (See also https://reason.com/2019/12/03/the-madcap-scheme-to-take-syrias-oil/ and the related...