Travelport, LP, Correspondence with the SEC Office of Global Security Risk (2012)

Date issued: Jun. 01 2012

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TURBOFAC Commentary (701 words)

Notes:

1) This letter describes the activities performed by the sort of "CRS" systems referenced in 020416-FACRL-CU-01, of which some, but not all, of the functionality was considered exempt from regulation under the Berman Amendment to TWEA for informational materials. In particular, the operational capability to book, pay for and ticket travel transactions on behalf of travelers was considered to not, in 2002, be permissible under the CACR, to which the Berman Amendment for travel does not apply.

2) SCOPE OF ACTIVITIES JUSTIFIED UNDER THE IEEPA TRAVEL EXEMPTION

In the letter the company references the Berman Amendment exemptions as the authority for its sanctioned country-related activities, along with what appear to be specific licenses, where the existence of the latter makes it...