OFAC Regulatory Provisions - 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.

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

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TURBOFAC Commentary (2155 words)

Notes:

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

The at 542.510 is OFAC effectively ceding to 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 13338.

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

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

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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.

TURBOFAC Commentary (2155 words)