Case No. SU-2014-311179-1

Date issued: Jan. 04 2016

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TURBOFAC Commentary (333 words)

Notes:

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...