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Case No. SU-2013-303493-1
Kathy Smith, Esq.
Office of Chief Counsel
U.S. Department of Commerce
1401 Constitution Ave.,
N.W. Room 4713
Washington, DC 20230
Dear Ms. Smith:
This responds to your application dated July 18, 2013 (the “Application”), to the Office of Foreign Assets Control (“OFAC”), on behalf of the National Telecommunications and Information Administration (“NTIA”), the Internet Corporation for Assigned Names and Numbers (“ICANN”), and VeriSign, Inc. (“VeriSign”) seeking to renew License no. SU-1652c. ICANN and Verisign, Inc. seek to continue to provide services needed to update specific administrative and technical information for the .sd domain, the country code top level domain associated with Sudan, under the oversight of the U.S. Department of Commerce. According to your conversation with an OFAC employee on July 29, 2013, VeriSign is a federal grantee under a...
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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...