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Case No. BU-2012-294603-1
[ ]
Assistant Vice President, Research and Global Health Initiatives
University of Maryland - Baltimore
Office of Research and Development
620 West Lexington Street,
4th Floor Baltimore, MD 21201
Dear [ ]:
This responds to your letters of May 21, 2012, June 13, 2012, July 2, 2012, and August 21, 2012 (the “Application”), to the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), on behalf of the University of Maryland – Baltimore (“UMB”), seeking a license to export or reexport financial services to Burma in support of UMB’s activities in Burma.
Except as otherwise authorized, the Burmese Sanctions Regulations, 31 C.F.R. Part 537 (the “BSR”), generally prohibit the exportation or reexportation of financial services to Burma, directly or indirectly, from the United States or...
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1) The general license to the now-repealed Burmese Sanctions Regulations (31 CFR part 537) is reproduced below:
General License No. 16
Authorizing the Exportation or Reexportation of Financial Services to Burma
(a) The exportation or reexportation of financial services to Burma, directly or indirectly, from the United States or by a U.S. person, wherever located, is authorized, subject to the limitations set forth in paragraphs (c), (d), and (e) of this general license.
(b) For the purposes of this general license, the term exportation or reexportation of financial services to Burma is defined in 31 CFR 537.305.
(c) This general license does not authorize, in connection with the provision of security services, the exportation or reexportation of financial services, directly or indirectly, to the Burmese Ministry of Defense, including the Office of Procurement; any state or...