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CASE No. NK-93053
Kathy D. Smith, Esq.
Chief Counsel
U.S. Department of Commerce
National Telecommunications and Information Administration
1401 Constitution Ave., N.W.
Washington, DC 20230
Dear Ms. Smith:
This in in reply to your September 12, 2006 letter to the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), on behalf of the Internet Corporation for Assigned Names and Numbers (ICANN) and VeriSign, Inc., in which you request guidance with respect to the provision of certain Internet-related interoperability services by the two companies on behalf of the U.S. Government for the maintenance of .kp, the country code top level domain associated with the Democratic People’s Republic of Korea, subject to the Foreign Assets Control Regulations, 31, C.F.R. Part 500.
To the extent authorization is needed, the provision of the...
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1) This letter deals with the same facts as those presented in Case No. SU-2013-303493-1 and Case No. SY-2012-295630-1, except that, here, the sanctioned country at issue was not subject to a comprehensive ban on the exportation of services from the U.S. A the time the letter was issued, North Korea was a country designated pursuant to the Foreign Assets Control Regulations, and subject to a broad blocking prohibition (500.201) that is virtually identical in scope to the current 515.201 of the CACR.
500.586 of the now-repealed FACR [1], which was in force for a brief period of time when U.S. sanctions vis-à-vis North Korea were at their least stringent in decades, authorized, with certain limitations, a wide range of previously prohibited transactions...