Case No. SU-2013-303493-1 [Application and related specific licenses included]

Date issued: Aug. 30 2013

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TURBOFAC Commentary (2853 words)

Consolidated Comment to Case No. SY-2012-295630-1 and Case No. SU-2013-303493-1

1) FACTUAL BACKGROUND

Case No. SY-2012-295630-1 and Case No. SU-2013-303493-1 are substantially similar guidance letters that help clarify the scope and operation of the standard exemptions and general licenses covering “transactions for the conduct of the official business of the Federal Government by employees, grantees, or contractors thereof”. The PDF file associated with this item contains both letters. For commentary on the “official business” provisions in general, see 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.

A notable (and unusual) characteristic of both of the letters is that they responses to requests for specific license renewals, where in one case OFAC concludes that no license is required, and in the other OFAC concludes...