Case No. CT-14564

Date issued: Sep. 15 2009

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TURBOFAC Commentary (153 words)

Notes:

1) The CACR as it existed at the time of the letter can be found at https://www.govinfo.gov/content/pkg/CFR-2009-title31-vol3/xml/CFR-2009-title31-vol3-part515.xml. Note that United States Tour Operators Association is a 501 registered nonprofit professional association representing the tour operator industry. Its members are made up of companies who provide services worldwide but who conduct business in the U.S.

2) At the time the license denial letter was issued, there was a specific licensing policy for "professional research and professional meetings" not otherwise generally licensed. OFAC found this request to be inconsistent with licensing policy at the time, but it is notable that 515.564 was cited at all in the denial, as it suggests that this sort of trip would qualify for the broader professional research and professional meetings GL that is in...