Case No. SY-2019-364717-1 [Application included]

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (2450 words)

Notes:

1.1) BACKGROUND - GENERAL

This guidance letter contains notable interpretations of the standard general license/exemption for “transactions for the conduct of the official business of the [Federal/ United States] Government by employees, grantees, or contractors thereof.”

Note that all provisions of the at issue here are, as of 4/2022, as they were when the guidance letter was issued. Of particular note, 542.211(d) is an “exempt transactions” provision that implements the “official business” exemptions found in certain Syria-related executive orders the prohibition of which were incorporated into the SySR, while the general license at 542.522 authorizes “official business” that would otherwise be prohibited by the SySR but were not based on executive orders that contained an “official business” exemption.

The guidance letter should be read in conjunction with our

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Case No. SY-2019-364717-1 [Application included]

TURBOFAC Commentary (2450 words)