Case No. SY-254

Date issued: Jan. 23 2012

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TURBOFAC Commentary (420 words)

Notes:

1) EXPORTATION FOR RESALE TO SANCTIONED PERSON IMPLICITLY COVERED BY AUTHORIZATIONS COVERING "EXPORTATION AND RE-EXPORTATION" TO SANCTIONED PERSON

At this time this guidance letter was issued, Syriatel was blocked pursuant to EOs 13460 and 13572. Syria GL 4, which has been implemented in the SySR as 542.510 [1], authorized “the exportation or reexportation of items subject to the [EAR]…to any other person whose property and interests in property are blocked pursuant to E.O. 13460...[, E.O. 13572]…and all transactions ordinarily incident thereto, as well as of services to install, repair, or replace such items, provided that the exportation or reexportation of such items is licensed or otherwise authorized by the Department of Commerce.”

What is requested here is authorization to export the goods to “Serta...