Case Nos. CU-77330, CU-77408, CU-77427 and CU-77518, and FAC No. CU-406608

Date issued: Jun. 11 2009

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TURBOFAC Commentary (186 words)

Notes:

1) See Civil Enforcement Information - United Nations Federal Credit Union, and query whether the violations at issue in that case were the "certain unauthorized financial transactions" described in this letter (note that OFAC would normally not provide voluntary disclosure credit for violations disclosed in the context of a letter to the licensing division).

2) At the time of this letter and prior, there was no "official business" GL covering UN-related transactions. See 515.562(b) (2015), Nov. 2014 Email from OFAC SC&E to Local Sudanese UNDP Staff in re: UNFCU Accounts, and query whether the transactions licensed here may qualify for the "official business" exemption if engaged in today.

3) Apart from the old licensing policy discernible from the letter, OFAC provides guidance of some potential relevance today, suggests that...