License No. SDGT-2021-372834-2

Date issued: Mar. 09 2022

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TURBOFAC Commentary (425 words)

Notes:

1) Compare the USAID West Bank/Gaza Licenses (2006-2013). This license appears to be the functional replacement for the series of licenses contained in the "USAID West Bank/Gaza Licenses" file.

2) There are some unusual aspects of the license, especially as compared to the previous versions.

First, why has any reference to the FTOSR been omitted? Hamas is still an FTO, and the purpose of the license is presumably to allow certain incidental U.S. person engagement with Hamas, including where such engagement involves the routing of payments through the U.S. financial system (thereby implicating 597.201). Perhaps

Second, what is the significance of the explicit addition, to the license, of "all other persons acting on their behalf" in "the United States government, including the Department of State, USAID, their...