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License No. SDGT-760f
GLOBAL TERRORISM SANCTIONS REGULATIONS
LICENSE AMENDMENT
(Granted under the authority of 3 I U.S.C. § 321 (b), 50 U.S.C. §§ 1601-1651, 1701-06, 22 U.S.C. § 287c, Executive Orders 13224 and 13372, and 31 C.F.R. Parts 501 and 594.)
To: United States Department of State
United States Agency for International Development
c/o Office of Terrorism Finance and Economic Sanctions Policy
United States Department of State
2201 C Street, NW
Washington, DC 20520
Attn: Linda Stuart Specht, Director
1. Based on the January 24, 2012 memorandum to the Office of Foreign Assets Control as well as the memoranda received on January 19, 2007, and July 3, 2008 (collectively, the "Application"), and information otherwise available to the Office of Foreign Assets Control, License No. SDGT-760e is hereby amended and the transactions and activities delineated herein are hereby authorized.
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1) As the time the specific license was issued, the then-SDGT Communist Party of Nepal-Maoist ("CPN-(M)") had won the most seats in the most recent Nepalese election (by plurality). (See https://en.wikipedia.org/wiki/2008_Nepalese_Constituent_Assembly_election). This specific license tracks others that are issued to the State Department and USAID for the purposes of engaging in transactions with sanctioned entities. See LICENSE No. SOM-2012-296153-1, LICENSE No. TCO-2016-338378-1 and the USAID West Bank/Gaza Licenses.
Here, as is the case with the other licenses, it is clear that the authorization for "U.S. persons who are grantees or contractors of [State and USAID]" extends to subcontractors thereof. See the native PDF file, in which the USAID FRP incorporates the OFAC license and actually requires subcontracting.
2) Section I(c) is, in effect, a reformulation of 594.405 of the