Case No. SY-2015-316218-1

Date issued: Mar. 30 2016

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TURBOFAC Commentary (247 words)

Notes:

1) The Applicant was a small Polish “foundation” focused on fundraising and using the funds to send humanitarian aid to Syria. In the year prior to the January 2015 guidance application, the Applicant had no employees, and had raised around $20.000 and had around $4,000 in cash. (See https://web.archive.org/web/20180831084316/http://wolnasyria.org/images/pdf2/sprawozdanie_z_dzialalnosci_2014.pdf, also in PDF). OFAC determines that the foundation’s “financial transactions in support of humanitarian aid sent to Syria” were capable of fitting within the nongovernmental organizations GL at 542.516. The guidance letter is notable for principally as an example of OFAC regarding a very small non-U.S. person entity as one that qualifies as a “nongovernmental organization” for purposes of the SySR NGO GL. See generally General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations...