Case No. MUL-372-1

Date issued: Nov. 28 2014

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (1613 words)

Notes

1) BACKGROUND

The Airline Tariff Publishing Company (ATPCO) is the primary entity, and possibly the only entity, that serves as a conduit between airlines and global distributions systems such as Sabre and large online travel agents, such as Travelocity. (See Sabre Corporation, 2019 10-K Filing, 2023 Q1 10-Q Filing), for information on Sabre's activities and their status as exempt).

In the first paragraph of the letter, OFAC recounts that APCO "collects fare data from and distributes passenger data to several airlines based in [sanctioned countries]," and that it "engages in these activities based on its understanding that certain exemptions from OFAC’s regulations may apply..."

See also https://www.atpco.net/legal/terms-of-use, explaining that ATPCO:

"collect[s] the fares and rules data instructed by airlines and distribute them to the GDSs, revenue management and revenue accounting systems, passenger...