Case No. SY-2015-316217-1

Date issued: Jul. 07 2018

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TURBOFAC Commentary (181 words)

Notes:

1) PS International, Ltd. Is a U.S. person “international trading company that specializes in the trading of bulk agricultural foodstuffs”. It has “expert trading teams…sourcing products from a variety of international origins and finding the lowest prices.” (https://www.linkedin.com/company/ps-international-ltd-/about/). This entity appears to be in the business of acting as a trading intermediary, i.e. by purchasing bulk goods and selling them at a higher price. To the extent that these are the “activities related to the export of non-U.S. origin bulk agricultural commodities to Syria,” it would be a notable application of 542.525 of the SySR, which authorizes “services that are ordinarily incident to the exportation or reexportation to Syria, including to the Government of Syria, of non-U.S.-origin food, medicine, and medical devices that would be designated as