Case No. SU-1915-1

Date issued: Aug. 24 2006

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TURBOFAC Commentary (315 words)

Notes:

1) The guidance letter refers to an “authorization [] published in the Defense Federal Acquisition Regulation Supplement [] on February 14, 2003”. See https://www.govinfo.gov/content/pkg/FR-2003-02-14/pdf/03-3572.pdf. That authorization provides as follows:

“DoD personnel are authorized to make emergency acquisitions in direct support of U.S. or allied forces deployed in military contingency, humanitarian, or peacekeeping operations in a country or region subject to economic sanctions administered by the Department of the Treasury, Office of Foreign Assets Control.” (See also https://www.ecfr.gov/current/title-48/chapter-2/subchapter-D/part-225/subpart-225.7/section-225.701-70).

See the original license at License No. [Redacted] 10-1-02.

The face of the specific license covers the making of “acquisitions,” but the guidance letter is seeking authorization with respect to a U.S. person’s ability to “provide goods, services and personnel to the United States Army in Sudan” (i.e. to...