LICENSE No. SY-2015-324638-1, 2 [Application Included]

Date issued: Sep. 17 2020

Last substantive commentary amendment:
May. 08 2023

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TURBOFAC Commentary (903 words)

Notes:

1) As of 2-27-23, these licenses are the only of their kind in the Research System. As evident from the application in the native PDF file (see p. 1), the applicant indirectly owned (i) 50% of one Syrian entity, of which the other 50% was owned by a blocked entity owned by an entity meeting the definition of Government of Syria, and (ii) 100% of a Swiss entity that was the owner of the applicant’s stake in the blocked Syrian joint venture. According to the application, the two entities were “dormant”, with no assets (except, in the case of the Swiss entity, its ownership interest in the Syrian entity).

2) According to the application, “[t]he apparent need for a license from [OFAC] is occasioned by [U.S. person applicant’s] need to interact with [Syrian Petroleum Company] (a blocked person) and other Syrian persons -including the Syrian government and...