31 CFR § 594.207 Exempt transactions

Date issued: Jul. 23 2019

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TURBOFAC Commentary (1900 words)

Note Specific to 594.207 of the GTSR

1) This "exempt transactions" provision does not include the usual IEEPA exemptions (travel, informational materials, personal communications) because the GTSR are issued pursuant to an EO that relies on UNPA for its authority, and UNPA does not provide for exemptions. This issue is discussed in detail at General Note on the Applicability of IEEPA/TWEA Exemptions in EOs and Sanctions Regulations not Specifically Mentioning Them (System Ed. Note).

Note here that there is no inconsistency between this provision and OFAC's position that UNPA provides for no exemptions. The exemptions in this provision apply only insofar as a designation is made pursuant to §594.201(a)(6) or (7). Those provisions implement designation...