DOJ Letter to Senate in re: Material Support Statute (2011)

Date issued: Aug. 12 2011

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TURBOFAC Commentary (434 words)

Notes:

1) This letter was sent by the Assistant Attorney General to the Chairman of the Senate Committee on the Judiciary around one week after OFAC published FAQ # 130, FAQ # 131, FAQ # 132, FAQ # 133 and FAQ # 134. Those FAQs were aimed at assuring NGOs that unintentional “technical violations” of the GTSR and/or FTOSR would not be “enforcement priorities” when the violations arose from the provision of incidental benefits to the FTO Al-Shabaab by humanitarian aid workers operating in areas controlled by that FTO. FAQ 134 says “To the extent that such a payment is made unintentionally by an organization in the conduct of its assistance activities, where the organization did not have reason to know that it was...