The Western Union Company (2006, 2013 and 2016 Correspondence With the SEC)

Date issued: Jul. 25 2006

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TURBOFAC Commentary (2124 words)

Notes:

1) Background

The various correspondence in the file associated with this item serves as a notable example of the way in one of the (if not the) world’s largest remittance service companies interprets the general licenses found in IEEPA-based embargoes for “noncommercial, personal remittances” involving sanctioned destinations.

One of the GLs addressed in the correspondence is the “General License, effective June 13, 2005 [t]hat license authorizes transmission of funds into Sudan by U.S. registered money transmitters, if those funds are ‘noncommercial, personal remittances’ for persons ordinarily resident in Sudan and such persons are not part of the Government of Sudan.” This is a reference to 538.528 of the now-repealed SSR, which provided as follows:

§ 538.528 Noncommercial, personal remittances.
(a) U.S. depository institutions, U.S. registered...