Case No. SY-2020-XXXXXX-1 (6/26/2020)

Date issued: Jun. 26 2020

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TURBOFAC Commentary (830 words)

Notes:

1) Substantially redacted guidance letter addressed to a U.S. "nonprofit organization" (i.e. a 501(c)(3) non-profit) that specializes in the production of building materials and other items used in refugee camps (Note that we received this letter directly from the addressee). The applicant requests authorization to export goods "to Syria specifically areas in Syria that appear to be controlled by Coalition forces for use in refugee camps," and to provide services of an unspecified nature.

2) INTERPRETATION OF 542.516

Note that this letter was issued prior to the 2021 amendment of 542.516 (the version of the SySR NGO GL in effect from May, 2014-November, 2021). One interpretation implicit in the letter is that the "nonprofit organization" that manufactures items could provide services that qualified for the GL authorizing...