Case No. SU-3797-1 [Application included]

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (2757 words)

Notes:

1) Background

This guidance letter contains notable interpretations of both the travel exemption and the standard general license for “for the conduct of the official business of the United States Government or the United Nations by contractors or grantees thereof.” [1] At all relevant times Sudan was subject to a comprehensive trade embargo. See general discussion of the “official business” license at 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.

First note the highly unusual gap between the application and the date of the license. Here it took OFAC nearly three years to respond, which typically indicates that the application was held up in inter-agency consultations (i.e. the question presented was not an easy one). Note however that all of the legal provisions at issue...

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Case No. SU-3797-1 [Application included]

TURBOFAC Commentary (2757 words)