Telephone and Data Systems, Inc., Correspondence with the SEC Office of Global Security Risk (2016)

Date issued: Nov. 09 2016

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TURBOFAC Commentary (51 words)

Notes:

1) Roaming agreements with third parties for telecommunications services in sanctioned countries considered to fall within the scope of the telecommunications-related GLs of the SSR and SySR. The language of 515.542(b) suggests that “roaming service agreements” are within the scope of the telecommunications GLs on a cross-programmatic basis.