General Note Common to “Provision of services” Interpretive Provisions (System Ed. Note)

Last substantive commentary amendment:
Dec. 10 2023

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TURBOFAC Commentary (5272 words)

Notes Common to "Provision of services" and "Provision and receipt of services" Interpretive Provisions (System Ed. Note)

 

1) BACKGROUND

 

This provision is substantively similar to a like provision contained in all non-abbreviated sanctions regulations involving the blocking of property, except that (i) the versions found in IEEPA-based embargo regulations (560.410 (ITSR), 510.405 (NKSR), 542.405 (SySR), 589.405 (Crimea)) cover services exported to an embargoed country, in addition to the provision of services to blocked persons and with respect to blocked property, and (ii) versions of this provision implemented 1-21-22 and thereafter are titled "Provision and receipt of services," instead of just "Provision of services," and there is a subsection specifying that "[t]he prohibitions on transactions contained in § [5XX].201 apply to services received in the United States or by U.S. perfsons, wherever located, where the...