Notable Corresp. w/ the SEC re: Sanctions - The Boeing Company, Correspondence with SEC Division of Corporation Finance (2009, 2012, 2015)

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TURBOFAC Commentary (866 words)

Notes:

* Links to 2009 and 2012 correspondence in main text of document.

1) The Informational Materials Exemption: Concerning the following statement in the 2015 letter:

During the period covered by the Staff’s comment, Boeing has sold flight navigation materials consisting of standard airway manuals (paper charts) to customers in the Sanctioned Countries pursuant to exemptions in the OFAC sanctions program for certain informational materials.[] In order to produce these materials, Boeing obtains aeronautical information publications from the Sanctioned Countries pursuant to information exchange arrangements entered into under the aforementioned OFAC exemptions. The table below sets forth the revenues for sales of flight navigation materials related to each of the Sanctioned Countries.

Strictly speaking, it is difficult to see how the "information exchange arrangements" and the procurement of the initial "aeronautical information publications" would not "relate[ ] to information or informational materials not...

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The Boeing Company, Correspondence with SEC Division of Corporation Finance (2009, 2012, 2015)

TURBOFAC Commentary (866 words)