Honeywell International Inc., Correspondence with SEC Office of Global Security Risk (2015), re: 2013 10-K Filing

Date issued: Jan. 08 2015

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TURBOFAC Commentary (389 words)

Notes:

1) Example of a publicly traded company appearing to report OFAC and BIS as having confirmed that certain downloadable software/data qualifies as "informational materials" for IEEPA exemption purposes and is not subject to the EAR. Refer to Notes Common to the "Information or informational materials" Definitional Provision (System Ed. Note).

"The NavDB service has previously been reviewed by both the U.S. Treasury Department’s Office of Foreign Assets Control ("OFAC") and the U.S. Commerce Department’s Bureau of Industry and Security ("BIS") and confirmed by these agencies as exempt information not subject to the Export Administration Regulations, 15 C.F.R. Part 730 et seq. ("EAR") and ruled as "publicly available" information. Accordingly, Honeywell’s provision of the NavDB service to Aeolus Air is...