31 CFR § 510.520 Transactions ordinarily incident to the exportation or reexportation to North Korea of items licensed or otherwise authorized by the Department of Commerce, and related services

Date issued: Feb. 15 2024

Last substantive commentary amendment:
Feb. 17 2024

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TURBOFAC Commentary (586 words)

Notes:

1) Up through the 2-15-24 implementation of this GL, there was a very complex and uncertain relationship between OFAC’s North Korea sanctions and the exportation of items that were licensed for export by BIS. This relationship is described in detail in General Comment on the Relationship Between the North Korea Sanctions Regulations and Export Controls Administered by the Dep’t of Commerce. In short, three prohibitions in the NKSR510.211 (facilitation), 510.206 (general exports) and 510.201 (blocking)—specify that the prohibitions “apply except to the extent provided in regulations, orders, directives, or licenses that may be issued pursuant to this part or pursuant to the export control authorities implemented by the U.S. Department of Commerce,” and OFAC appeared to interpret those provisions as...