Case No. UKRAINE-EO13685-2018-350266-1

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TURBOFAC Commentary (568 words)

Notes:

1) BACKGROUND

NIIR (“Radio Research & Development Institute”) is a Moscow-headquartered Russian “Federal State Budgetary Institution,” i.e. an entity that operates under the jurisdiction of the federal government and is funded through the federal budget, which among other activities, operates testing centers with experience in testing equipment for information and communication technologies. (See www.niir.ru).

As explained in the guidance letter NIIR operated “TC NIIR” a “testing facility in Moscow” that the U.S. person applicant wanted to engage notwithstanding that TC NIIR “has a possible connection to Omega, another testing facility in the Crimea region of Ukraine”. OFAC, evidently conducting its own research on NIIR, concluded that “however the Omega website no longer works and in conducting web searches it appears Omega was combined with NIIR.”

2) INDIRECT IMPORTATION OF SERVICES THROUGH ENGAGEMENTS WITH NON-SANCTIONED THIRD-COUNTRY/JURISDICTION ENTITIES

The

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Case No. UKRAINE-EO13685-2018-350266-1

TURBOFAC Commentary (568 words)