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Case No. MUL-2012-298212-1
Peter L. Flanagan, Esq.
Covington & Burling LLP
1201 Pennsylvania Ave., N.W.
Washington, D.C. 20004
Dear Mr. Flanagan:
This responds to your request to the Office of Foreign Assets Control ("OFAC") for interpretive guidance dated October 4, 2012, on behalf of the American Petroleum Institute ("API"), a U.S. non-profit trade association representing America’s oil and natural gas industry, and to supplemental correspondence from API dated April 22, 2013, and August 27, 2013 (collectively, the "Request"), requesting guidance from OFAC. In the Request, you state that API is a leader in the development of petroleum and natural gas equipment and operating standards and that API maintains more than 600 standards and recommended practices, many of which have been incorporated into state and federal regulations.
The Request seeks guidance...
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1) GEN. NOTE ON THE 2012-2018 ANSI/API CORRESPONDENCE:
This guidance/license is one of six letters from OFAC that all stem from the same application. In 2012, American National Standards Institute ("ANSI") requested guidance on standards-setting activities and works related thereto under the Berman Amendment and Publishing GLs for multiple countries. OFAC replied in 2012 with Case No. IA-2012-293254-1 (application included in relevant PDF), and that reply prompted a request for clarification from the American Petroleum Institute, to which OFAC responded in 2014 (MUL-2012-298212-1) in a way that appeared to dampen the impact of the 2012 guidance to ANSI. ANSI then reacted to that with another request for guidance in 2015 (application included in relevant PDF) which was responded to from 2016 through 2018 in four parts, one for each embargoed country addressed (IA-2015-318205-1 [Iran], SU-2015-323915-1- [Sudan], License No. DPRK-2015-323913-1 [North Korea]...