CASE No. NK-93053

Date issued: Oct. 06 2007

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TURBOFAC Commentary (347 words)

Notes:

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500.586 of the now-repealed FACR [1], which was in force for a brief period of time when U.S. sanctions vis-à-vis North Korea were at their least stringent in decades, authorized, with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...