31 CFR § 510.512 - Certain services in support of nongovernmental organizations' activities. (Includes prior version)

Date issued: Feb. 15 2024

Last substantive commentary amendment:
Feb. 17 2024

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (646 words)

Notes:

1) The NKSR NGO GL is quite irregular vis-a-vis the typical NGO GL. For comments on the aspects of NGO-related GLs such as this that are conducive to cross-programmatic comment, refer to General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note).

2) On 2-15-24, OFAC amended 510.512 to make significant changes to the prior version (see left side of screen, bottom). The key difference between the 2-15-24 and previous versions are as follows:

(i) the list of " non-commercial activities designed to directly benefit the civilian population" qualifying for the GL has been altered such that it is not broadly in line with the list found in the standard list-based NGO GL (compare e.g. 558.512), except that the "activities...