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Case No. SU-2014-311179-1
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Pancrop Commercial Co. Ltd.
Al Emarat Street Khaitoum Sudan
Dear Mr. El [ ]:
This responds to your request dated July 9, 2014 (the "Application"), on behalf of Pancrop Commercial Co. Ltd. ("Pancrop"), a Sudanese company, to the Office of Foreign Assets Control (OFAC), requesting a license to conduct banking transactions in U.S. dollars in relation to Pancrop's provision of services to the United Nations. According to the Application, Pancrop is a Sudanese incorporated entity with offices in the United Arab Emirates and Sudan. The Application states that Pancrop holds several catering and transportation contracts and purchase orders for the supply of general goods for missions in certain areas, including South Sudan, Sudan, Lebanon, Syria, Mali, and the Ivory Coast.
The Sudanese Sanctions Regulations (31 C.F.R. Part 538) (SSR) block all...
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1) This guidance letter is a notable addition to the corpus of Research System guidance letters dealing with the official business exemptions and/or general licenses. Of particular note, this is an example of an application of “official business” where there is no reason to believe that the transactions at issue (“conduct banking transactions in U.S. dollars in relation to Sudanese entity’s provision of services to the United Nations”) would have any U.S. nexus other than involvement of U.S. banks. See section 9 of General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof. Compare Case No. SU-2015-315714-1 (similar).
In addition, the letter confirms, in a way that is not inconsistent with other items discussed in General Note on Exemptions and General Licenses...