ENF 22663 (No Action Letter with Underlying Disclosures)

Date issued: Jun. 27 2012

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TURBOFAC Commentary (139 words)

Notes:

1) This is one of two No Action Letter samples in the Research System (see also ENF 51470 (Sample No Action Letter). In OFAC Descriptions of 17 Huawei-related VSDs and Dispositions, OFAC describes its decision to close this case with a No Action Letter as follows: "Chengdu Huawei Symantec Technologies Co. Ltd. (“Huawei Symantec”) submitted disclosures to OFAC and BIS which indicated that some of Huawei Symantec’s products may have ultimately been shipped by third party resellers to Iran or Sudan. Huawei Symantec is not a U.S. person and there is no indication that a U.S. person exercised control or authority over any of the third party resellers involved in the de-minimis sales in Sudan or Iran. Therefore, OFAC Enforcement issued Huawei Symantec a No Action Letter."
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