Case No. SU-2015-315714-1

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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).

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TURBOFAC Commentary (400 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 (400 words)