License No. SDGT-760f

Date issued: Feb. 29 2012

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TURBOFAC Commentary (427 words)

Notes:

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