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Case No. Ukraine-EO13685-2015-318232-1
[ ]
Nautel Maine Inc.
201 Target Industrial Circle
Bangor, ME 04401
Dear Ms. [ ]:
This responds to your request dated April 13, 2015, as supplemented on June 17 2015, June 22, 2015, July 15, 2015, May 6, 2019, and June 19, 2019 (collectively, the "Application"), on behalf of Nautel Maine Inc. ("Nautel"), to the Office of Foreign Assets Control (OFAC), requesting guidance on exporting certain goods to Russia. According to the Application, Nautel produces the Navtex transmitter system, which provides the means to broadcast navigational and meteorological warnings and forecasts, as well as provide urgent marine safety information, to ships at sea. You further state that [***]. According to the Application, you seek guidance from OFAC on exporting the Goods to Russia because of the sanctions currently imposed on Russia.
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1) At the time this guidance letter was issued (and as of the date on which the letter was added to the Research System), OFAC administered a comprehensive embargo on Crimea, which extends to “any maritime area over which sovereignty, sovereign rights, or jurisdiction is claimed based on purported sovereignty over that land territory.”
The applicant produces “the Navtex transmitter system, which provides the means to broadcast navigational and meteorological warnings and forecasts, as well as provide urgent marine safety information, to ships at sea.” See https://www.danphone.com/media/2034/danphones-navtex-brochure.pdf. The applicant wanted to export those goods to Russia, more specifically “Radio Complex and FSUE Rosmorport in Russia”. FSUE Rosmorport manages and operates NAVTEX coastal stations, including one that is close to, but not located in, Crimea (https://en.portnews.ru/news/346188/).
OFAC concludes that no specific license is required...