Case No. BU-2013-302061-1 [Application included]

Date issued: Jun. 14 2013

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TURBOFAC Commentary (3648 words)

Notes:

1) Background

Case No. BU-2013-302061-1 contains some consequential "ordinarily incident" determinations as it relates to financial services, in particular financing activities, incident to the exportation of goods. The letter also contains important determinations speaking to the scope of the exemptions and licenses covering “transactions for the conduct of the official business of the U.S. Government by employees, grantees, or contractors thereof.” Read in conjunction with Case No. BU-2013-302061-1, which is a sort of "companion case" (letter issued to the Overseas Private Investment Corporation (“OPIC”) concerning the same sanctions regulations and "official business" exemption, and dated close in time to this letter). Refer generally to General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof.

The Export-Import Bank of the United States (Ex-Im Bank or Ex-Im)...