From: [REDACTED]
Sent: Monday, November 24, 2014 3:13 PM
To: OFAC_Feedback
Subject: UN local staff in Sudan (General license-Sudanese Sanctions Regulations "SSR")
Importance: High
Dear Madam/Sir,
Good Afternoon,
I am writing to you concerning the SRR General License. I would like to seek your kind advise if the UN local staff in Sudan (Sudanese) is under the general license waiver in reference to their salary payments in US dollars through UNFCU (The UN bank).
For your reference kindly, note that I am working as a local UN staff in the United Nations Development Programme (UN agency) at Sudan.
I would like to make sure that my salary payment in US dollars through UNFCU is not preaching* US sanction on Sudan.
Thanks in-advance for your kind advise.
[REDACTED]
* * * * * * * * * *
From:
[email protected] [mailto:
[email protected]]...
1) The now-repealed SSR, as they existed as of 2014, are available here. Note that, at the time of the emails, Sudan was subject to a comprehensive IEEPA-based embargo.
The context of the inquiry to and reply from OFAC’s Sanctions Compliance & Evaluation unit was the United Nations Federal Credit Union having closed accounts for certain local Sudanese United Nations Development Programme (UNDP) staff members, citing OFAC regulations as the reason for the closure (see pp. 1-2 of native PDF file).
The United Nations Federal Credit Union, which was subject to an OFAC enforcement action in 2010, is a not-for-profit cooperative that, for OFAC purposes, is an ordinary “U.S. person.” According to the UN-produced letter at p. 5 of the native PDF file,...