Case No. SU-1917

Date issued: Aug. 24 2006

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TURBOFAC Commentary (920 words)

Notes:

1) BACKGROUND

While old, this is a notable guidance letter concerning the scope of the “official business” exemptions and general licenses.

At the time the guidance letter was issued, there was a broad embargo against Sudan with an exemption at 538.211(e) stating that the “prohibitions contained in [the SSR] do not apply to transactions for the conduct of the official business of the Federal Government or the United Nations by employees thereof.”

2) THE UNITED NATIONS (INCLUDING) EMPLOYEES THEREOF?

The language of the SSR exemption “the United Nations by employees thereof” stands in contrast to the typical “official business” GL and exemption language, which covers transactions of the “United Nations…by employees, grantees, or contractors thereof”. Indeed the SSR were amended on Oct. 31, 2007 (72...