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Case No. SY-2015-316217-1
David R. Kuntarich
PS International LLC dba PS International, Ltd.
1414 Raleigh Road, Suite 205
Chapel Hill, NC 27502
Dear Mr. Kuntarich:
This is in response to your request of January 26, 2015 (the “Application”), on behalf of PS International LLC dba PS International, Ltd. to the Office of Foreign Assets Control (OFAC), in which you seek authorization to conduct activities related to the export of non-U.S. origin bulk agricultural commodities to Syria.
The Syrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR), block all property and interests in property that are in or come within the United States, or that are in or come within the possession or control of any U.S. person, including any foreign branch, of the Government of Syria and of certain other persons. SySR, § 542.201. The SySR...
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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