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GLOBAL TERRORISM SANCTIONS REGULATIONS
LICENSE RENEWAL
(Granted under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, 22 U.S.C. § 287c, Executive Orders 13224 as amended, and 31 C.F.R. Parts 501 and 594.)
To: The U.S. Department of State
Bureau of Economic Affairs
Washington, DC 20520
Attn: Andrew Weinshenk
Director, Office of Threat Finance Countermeasures
1. Based upon the request dated February 4, 2022 and additional correspondence dated February 9 and 15, 2022, to the Office of Foreign Assets Control (the “Application”) the transactions described herein are hereby authorized. This license supersedes SDGT-2021-372834-1 in all respects.
2. This License is subject to the condition, among others, that the Licensees comply with its terms and with all regulations, rulings, orders, and instructions issued under any of...
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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...