Case No. MUL-2014-315008-1 - [Application included in Original PDF]

Date issued: Oct. 03 2015

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TURBOFAC Commentary (65 words)

Notes:

1) For substantive analysis see comments to Guidance on Certain Publishing Activities (2016), which is essentially a de-personalized copy of this guidance, adapted for public consumption. Note that the application attached to the original PDF file of this letter is helpful context for understanding the 2016 guidance, and relays guidance from OFAC concerning the concept of "acting on behalf of" a sanctioned government.