License No. SU-2014-314079-1

Date issued: Aug. 03 2015

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TURBOFAC Commentary (275 words)

Notes:

1) For the SSR as they existed at the time of the issuance of the license, see https://www.govinfo.gov/content/pkg/CFR-2015-title31-vol3/xml/CFR-2015-title31-vol3-part538.xml. A notable aspect of the license, apart from OFAC having exercised its discretion to issue is, is the reference to 538.525 (“Payment may be made by cash in advance, open account financing, or letter of credit to be issued by third-country financial institution that is not a U.S. person, consistent with the provisions of 31 C.F.R. section 538.525”). 538.525 set out “Payment for and financing of commercial sales of certain agricultural commodities, medicine, and medical devices.” The GL addressed payment terms for “agricultural commodities that do not fall within the definition of food set forth in § 538.523(a)(3)(ii)”. The suggestion is that OFAC considered the “U.S.-origin solar powered pump systems and solar...