Guidelines on Transactions with the Palestinian Authority

Date issued: Jul. 20 2006

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TURBOFAC Commentary (416 words)

Notes:

1) See LICENSE No. SDGT-2012-298681-1, comments thereto, for what appears to be a license issued in contemplation of the possibility of dealings that, as a result of Hamas involvement, would not fall within the scope of the GL.

2) Guidelines issued prior to the technical amendment to GL 7. See Note Common to GTSR/FTOSR/TSR GL 7 and 7(a), 594.516, 595.514 and 597.512.

3) The FTOSR require U.S. financial institutions to block all funds in which "agents" of FTOs have an interest, and "agent" is defined as "any person to the extent that such person is, or has been, or to the extent that there is reasonable cause to believe that such person...