General Note on the Cross Programmatic Relevance of TSRA, as it relates to Agricultural Commodities, Medicine and Medical Devices (System Ed. Note)

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TURBOFAC Commentary (5373 words)

General Note on the Cross Programmatic Relevance of TSRA, as it relates to Agricultural Commodities, Medicine and Medical Devices (System Ed. Note)

1) BACKGROUND

The Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”), 22 U.S.C. §§ 7201-7211, contains several provisions of wide-ranging application, of which the precise operation is generally not made explicit by OFAC in regulations, executive orders or other guidance. The purpose of this Note is not to discuss the scope and application of TSRA in an exhaustive fashion.

Rather, it is to identify the scope of the statute in a way that allows for one to understand how it does and does not have an impact on OFAC's licensing policies in situations where such impacts are not otherwise made clear from the law and other associated guidance. More specifically, the purpose of the note...