Case No. SY-32 FAC No. SY-241825

Date issued: Jul. 25 2005

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TURBOFAC Commentary (153 words)

Notes:

1) Guidance letter issued prior to the OFAC-administered service ban vis-à-vis Syria (which has been tempered by 542.525 and 542.510 of the SySR). See General Note on the Syrian Sanctions Regulations and the Relationship Between the Authorities Underlying the Regulations for further discussion of the relationship between the SAA, EAR and OFAC-administered service prohibitions.

Note—and this is of consequences for the operation of the current 542.510 of the SySR—that OFAC considers exports of U.S.-origin food and medicine to be "licensed" by BIS (rather than outside of BIS’ jurisdiction altogether). The language used in this letter ("[BIS] is responsible for licensing all exports and reexports, including food and medicine, to Syria") is consistent...