Case No. SU-3464

Date issued: Sep. 27 2010

Last substantive commentary amendment:
Sep. 03 2023

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (1122 words)

Notes:

1) BACKGROUND

“Tristar Transport LLC” is a (and was) a large, Dubai-based energy logistics provider with operations in various countries (https://www.tristar-group.co). The company was (and is) a significant provider of goods and services to the United Nations. See e.g. https://content.unops.org/publications/ASR/ASR-2010_EN.pdf, detailing the procurement of ~$23 million worth of energy-related products in 2010. There is no reason to believe that Tristar could have been considered a “U.S. person” for the purposes of this guidance letter (and it is unlikely that it would have made a difference).

2) U.S. PERSON ACTING IN FURTHERANCE OF NON-U.S. PERSON ‘CONTRACT’

The “official business” GL cited in the letter covers “transactions for the conduct of the official business of the United Nations specialized agencies by employees, contractors, or grantees thereof.” In this case, the...