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§594.207 Exempt transactions.
The prohibitions contained in §594.201(a)(6) and (7) do not apply to the following activities:
(a) Any authorized intelligence, law enforcement, or national security activities of the United States; or
(b) Any transaction necessary to comply with United States obligations under the Agreement between the United Nations and the United States of America regarding the Headquarters of the United States, signed at Lake Success June 26, 1947, and entered into force November 21, 1947, or the Convention on Consular Relations, done at Vienna April 24, 1963, and entered into force March 19, 1967, or any other United States international agreement.
[84 FR 35312, July 23, 2019]
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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...