LICENSE No. TCO-2016-338378-1

Date issued: Feb. 03 2017

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TURBOFAC Commentary (606 words)

Notes:

1) The native PDF file contains LICENSE No. TCO-2016-338378-1, as well as the letter from USAID to the UNDP transmitting the grant and its associated terms. USAID asserted "deliberative process privilege" over the State Department memorandum referenced in the authorization section of the license.

2) The license and its associated documents are notable for a few reasons. First, compare the license with, e.g., LICENSE No. SOM-2012-296153-1 and the USAID West Bank/Gaza Licenses. Direct and indirect dealings with sensitive SDN organizations, where they are permitted at all, appear to commonly go through USAID (with the State Department acting as a liaison between the OFAC and USAID).

3) Second, note that while the authorization applies on its face to "the United States Department of State, United States Agency for International Development (USAID),...