License No. [Redacted] 10-1-02

Date issued: Oct. 01 2002

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TURBOFAC Commentary (96 words)

Notes:

1) This license was released by the Office of the Under Secretary of Defense for Acquisition & Sustainment. It is the only license of which we are aware that has no expiration date and applies to all OFAC-administered sanctions programs, including those that had not yet been issued as of the time of the issuance of the license.

To the extent that his license is still valid, it would explain why there are no general licenses that explicitly cover this activity.

[1] https://www.acq.osd.mil/dpap/dars/pgi/si_docs/225.7%20License.pdf