CASE No. GEN-410

Date issued: Mar. 31 2009

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TURBOFAC Commentary (706 words)

Notes:

1) “PERSON SUBJECT TO THE JURISDICTION OF THE UNITED STATES”

The particular sanctions program at issue in the guidance letter is the FACR, which existed from 1950 up through 2011, and for most of its existence was the program pursuant to which North Korea was comprehensively sanctioned. The FACR were structured in a manner that is almost identical to the current CACR, so certain interpretations of the FACR can have ongoing relevance to certain provisions of the CACR, i.e. those that contained nearly identical language and were generally interpreted in a harmonious manner. The FACR as they existed at the time of the letter can be found at https://www.govinfo.gov/content/pkg/CFR-2009-title31-vol3/xml/CFR-2009-title31-vol3-part500.xml.

Like 515.201 and 515.204 of the CACR, 500.201 and 500.204 of the FACR...