Nov. 2014 Email from OFAC SC&E to Local Sudanese UNDP Staff in re: UNFCU Accounts

Date issued: Nov. 24 2014

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TURBOFAC Commentary (869 words)

Notes:

1) The now-repealed SSR, as they existed as of 2014, are available here.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,...