PayPal Holdings, Inc. (2016 Correspondence With the SEC)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (323 words)

Notes:

* The version of the in force as of the time of the correspondence can be found at https://www.govinfo.gov/content/pkg/CFR-2020-title31-vol3/xml/CFR-2020-title31-vol3-part542.xml#seqnum 542.516. Note that the below was drafted prior to the November, 2021 revisions to 541.516.

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The key passage in the correspondence is the following:

With respect to Syria, pursuant to a general license from OFAC in the Syrian Sanctions Regulations, PayPal may process transactions related to the export of services in support of certain authorized humanitarian and other not-for-profit activities in Syria by U.S. and third country non-governmental organizations. In each instance, the nexus to Syria would be indirect. The transactions processed by PayPal involved payments (e.g., donations) to a U.S. or third country non-governmental organization for the benefit of humanitarian or other not-for-profit activities that such non-governmental organization may conduct in Syria.

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PayPal Holdings, Inc. (2016 Correspondence With the SEC)

TURBOFAC Commentary (323 words)