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Case No. SOUTH SUDAN-2014-310204-1
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Sudan Education for Liberty Foundation
911 De La Vina
Santa Barbara, CA 93101
Dear [ ]
This is in reply to your request dated March 4, 2014 to the Office of Foreign Assets Control (OFAC), requesting authorization related to financial transactions, specifically wiring money to the Kenyan Central Bank in South Sudan to pay teachers employed by your organization.
Except for certain exemptions and general authorizations, the Sudanese Sanctions Regulations (SSR), 31 C.F.R. Part 538, prohibit the exportation or reexportation, directly or indirectly, to Sudan of any goods, technology, or services from the United States or by a U.S. person, wherever located, or requiring the issuance of a license by a federal agency. The SSR also prohibit U.S. persons from dealing in property and property interests of...
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1) The letter responds to a request made prior to the issuance of the South Sudan Sanctions Regulations, but after the issuance of the EO that serves as the basis for those regulations. In addition, the now-repealed Sudanese Sanctions Regulations were still in effect. The impetus of the request was most likely a lack of understanding as to the non-sanctioned nature of South Sudan as a whole. Compare e.g. Case No. MUL-270.