Guidance for the Provision of Humanitarian Assistance to the Palestinian People

Date issued: Nov. 14 2023

Last substantive commentary amendment:
Feb. 16 2024

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (1243 words)

Notes:

1) Read in conjunction with Supplemental Guidance for the Provision of Humanitarian Assistance, which provides an overview of the GLs described in this document, but not in the particular context of the Palestinian territories and the FTOs that operate there.

2) The most notable aspect of this document, in terms of OFAC breaking new ground in a way that can moves the ball forward on interpretive issues, is the statement that " Foreign persons do not risk exposure to U.S. sanctions for engaging in activity for which a U.S. person would not need a specific license issued pursuant to the GTSR or FTOSR." This statement, while consistent with OFAC's general policy as it relates to the application of secondary sanctions and de facto secondary sanctions to activities for which U.S....