Case No. SU-2464-1

Date issued: Feb. 11 2007

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TURBOFAC Commentary (419 words)

Notes:

1) Several guidance letters in the Research System confirm that the provision of general banking services to UN agencies is authorized by the standard official business exemptions/GLs (see e.g. Case No. SY-2012-298921-1), but this case is notable for the fact that OFAC appears to categorically take the position that all UNAMID-related transactions are covered. However, UNAMID, as suggested in the letter, is a “hybrid” operation (a sort of intergovernmental JV) between the UN and the African Union, the latter of which is not covered by the official business GL at issue here. For more information on UNAMID, see https://en.wikipedia.org/wiki/United_Nations_Security_Council_Resolution_1769, https://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/CAC%20SRES%201769.pdf and https://digitallibrary.un.org/record/601024?ln=en&v=pdf, as well as the below for an overview of the split responsibilities:

As stated in the communiqué of the African Union Peace and Security Council f 30 November,...