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Case No. BU-2013-301644-1

Date issued: Dec. 16 2013

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Case No. BU-2013-301644-1

Insyndia Global
605 1st Ave., Ste. 350
Seattle, WA 98104
Attn: Alec Harris

Dear [ ]:

This responds to your letter of April 2, 2013 (the “Application”), to the Office of Foreign Assets Control (“OFAC”), on behalf of Insyndia Global (“Insyndia”) and Rune Information Security Corporation (“Rune”), requesting interpretive guidance as to whether Insyndia can provide network auditing services, and whether Rune, a security software company owned by Insyndia’s principals, can export encryption hardware, to the Burmese Ministry of Defense (“MOD”). Your Application states that Insyndia’s network auditing services for the MOD would include an audit of the MOD’s network and communications security and recommendations on policy and hardware upgrade solutions. Rune would provide the encryption hardware. WinWinWin International Co. (“Win”), located in Rangoon, Burma, is the local broker for the deal.
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TURBOFAC Commentary (1089 words)

Notes:

1) Background; the Then-applicable Law
The guidance was requested while the Burmese Sanctions Regulations (31 CFR part 537) (BSR) were still in effect. The BSR were, as of the time of the issuance of the guidance letter, relatively complex, with a broad-based prohibitions on the exportation of imports of articles from Burma and exportation of financial services to Burma, both of which were tempered by a complex general licensing scheme (https://www.govinfo.gov/content/pkg/CFR-2013-title31-vol3/xml/CFR-2013-title31-vol3-part537.xml). Of note, the "term exportation or reexportation of financial services to Burma [was] defined in 537.305 of the Regulations [] to mean any activity with a monetary aspect, including, but not limited to, banking services, insurance services, and brokering services." (70 FR 48239, emphasis added). There was no broad...