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Case No. SU-1788
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Afripayments LLC
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Owings Mills, MD 21117
Dear Mr. [ ]:
This is in response to your letter of February 14, 2006, on behalf of Afripayments LLC, to the Office of Foreign Assets Control ("OFAC"), in which you request a specific license to establish and operate a money transfer service from the United States to Sudan.
The Sudanese Sanctions Regulations, 31 C.F.R. Part 538 (the "SSR") prohibit the importation or reexportation, directly or indirectly, of any goods, technology, or services, including financial services, from the United States or by a U.S. person, wherever located, to Sudan. SSR, § 538.205. The facilitation by a U.S. person, including but not limited to brokering activities, of the exportation or reexportation of goods, technology, or services to or from Sudan is prohibited. SSR,...
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This guidance letter interprets a provisions [1] of the now-repealed SSR that are broadly parallel to provisions in the NKSR (510.511/510.329), SySR (542.512/542.323) and Ukraine General License Number 6 (but not the ITSR).
[1] See https://www.govinfo.gov/content/pkg/CFR-2007-title31-vol3/xml/CFR-2007-title31-vol3.xml
As long as an entity (even a small startup, as the case with the correspondent at issue here) is properly registered with FinCEN in accordance of the current equivalent of 31 CFR 1022.380, it may process noncommercial remittances in accordance with the applicable general license. Further information about the entity at issue...