Case No. SU-2013-306171-1

Date issued: Feb. 01 2016

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TURBOFAC Commentary (688 words)

Notes:

1) NOTABLE INTERPRETATION OF A “RELATED TO/RELATING TO” GL

At the time this guidance letter was issued, Sudan was still subject to a comprehensive embargo, but there was a GL that read as follows:

§ 538.536 Activities relating to the petroleum and petrochemical industries in the Republic of South Sudan.

(a) To the extent they are not exempt from the prohibitions of this part, all activities and transactions relating to the petroleum and petrochemical industries in the Republic of South Sudan are authorized, including but not limited to the transshipment of goods, technology, and services to or from the Republic of South Sudan through Sudan; exploration; development; production; field auditing services; oilfield services; activities related to oil and gas pipelines; investment; payment to the Government of Sudan or to entities owned or controlled by the Government of Sudan...