LICENSE NO. SDG-597-c, LICENSE NO. SDG-597-f, LICENSE NO. SDG-597-g, LICENSE NO. SDG-597-i, LICENSE No. SDGT-2012-298681-1, LICENSE No. SDGT-2012-298681-3

Date issued: Nov. 29 2012

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TURBOFAC Commentary (946 words)

Notes:

1) BACKGROUND

In 2006, OFAC determined that:

"Following the January 2006 Palestinian elections, Hamas, a designated terrorist entity whose property and interests in property are blocked pursuant to §597.201, has been determined to have a property interest in the transactions of the Palestinian Authority. Accordingly, pursuant to §597.201, U.S. persons are prohibited from engaging in transactions with the Palestinian Authority unless authorized." (See e.g. 597.407). This applies to the TSR, FTOSR and GTSR, as Hamas is designated pursuant to all three.

In 2007, OFAC issued FTOSR/GTSR/TSR GL 7, providing that "U.S. persons are authorized to engage in all transactions otherwise prohibited under this part with the Palestinian Authority."

This file includes six specific licenses dated 2007-2015 that, "to the extent authorization is...