Case No. SU-3797-1
Stephanie Roberts
Indiana University
Office of Research Administration
509 E. Third Street
Bloomington, IN 47401-3654
Dear Ms. Roberts:
This is in response to your July 8, 2011 request to the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), requesting authorization to pay for activities conducted under a grant from the U.S. Department of Education for funding as a Comprehensive National Resource Center with Foreign Language and Area Studies. Specifically, you sought authorization to draw upon the grant for Professor Beth Samuelson's work developing an exchange with the Teachers of English to Speakers of Other Languages (TESOL) Association of Sudan, including support for Khaleel Ismail and his travels to Indiana University and Professor Samuelson's travel to Khartoum, Sudan, for her presentation at the December 2011 TESOL Sudan conference at Khartoum University in Khartoum, Sudan.
Except for certain exemptions and...
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...