31 CFR § 542.525 - Exportation or reexportation of services to Syria related to the exportation or reexportation of certain non-U.S.-origin goods authorized.

Date issued: May. 02 2014

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TURBOFAC Commentary (2125 words)


1) Compare 542.510. These are completely different GLs, though they appear similar in certain respects.

The GL at 542.510 is OFAC effectively ceding to BIS the jurisdiction that OFAC has over exports of goods to blocked persons in Syria.

This GL, on the other hand, deals with situations that are generally out of BIS jurisdiction altogether, i.e. the export of non-U.S. origin products outside of the U.S.

As important background for understanding the scope of this GL, note that the prohibitions on the exports of goods to Syria that are administered by BIS derive from Sec. 1(b) of EO 13338.

Sec.1(b) of EO 13338 provides as follows:

(b) Except to the extent provided in regulations, orders, directives,...