Case No. SU-2015-315714-1

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TURBOFAC Commentary (385 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. First, this is, as of the date on which it was added, one of two letters in the Research System where the sanctions nexus in an “official business” transaction is that the provider of goods or services is a sanctioned person. Typically, there are non-sanctioned persons providing services to or in sanctioned countries, and this is the reason why the official business authorization is needed, whereas here the letter contemplates official business transactions where a Sudanese entity provides goods and services to non-sanctioned destinations on behalf of the UN. Now that there are “official business” provisions in all list-based blocking programs, this letter may be more relevant than it would otherwise be (e.g. a Russian ...

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Case No. SU-2015-315714-1

TURBOFAC Commentary (385 words)