Case No. SOM-562725

Date issued: Nov. 10 2011

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TURBOFAC Commentary (413 words)

Notes:

1) Read in conjunction with FAQ 130, FAQ 131, FAQ 132 and FAQ 133. Those FAQs were initially released on August 4, 2011, three months prior to the date of this letter. Clearly, the "soft safe harbor" provided in FAQ 132 regarding incidental benefits provided to the FTO al-Shabaab was not broad enough to cover the full range of Somalia-related activity envisaged by certain NGOs. Further background concerning the context of this letter can be found in the United Nations Office for the Coordination of Humanitarian Affairs' "Study of the Impact of Donor Counter Terrorism Measures on Principled Humanitarian Action" (2013), avail. at https://www.unocha.org/sites/unocha/files/CounterTerrorism_Study_Full_Report.pdf.

2) The USAID license referred to in the letter is presumably License No. SOM-7a, of which most of the authorization section is quoted in the comments to...