[Ws2-jurisdiction] Proposed Final OFAC Recommendation for Plenary

Greg Shatan gregshatanipc at gmail.com
Wed Sep 20 05:18:01 UTC 2017


As discussed on Monday's call, the plan is to submit the OFAC
Recommendation for consideration by the Plenary in next week's call.  The
document deadline for next week's plenary is 23:59 UTC on Wednesday,
September 20.

As promised on Monday's call, I revised the draft recommendation in Google
Docs to reflect the discussions on the call and then circulated PDF and
Word copies to the list for review and comment.  I received comments from
Milton Mueller on the list, which were consistent with the Monday call, and
the draft has been updated with these comments.

I am attaching PDF and Word copies of the latest version of the OFAC
Recommendation, which I believe is very close to final form.  I have
included a clean copy of the proposed final version, and a version with
track changes, showing the changes to the pre-call version of the
Recommendations.  IF you want to read the Recommendation, I think the clean
version is much easier to follow.  The track changes version is useful if
you want to see what changes are made.

So that we may have a Google Doc that shows the proposed final OFAC
Recommendation as it will be submitted (i.e., without revisions and
comments), I have created a new Google Doc, which I encourage you all to
read over one more time before it goes to the plenary.   The link is:

https://docs.google.com/document/d/1xLDx7IevK2s7yQ1naD3cjnlPGnO7oPrRUN61RKEesFc/edit?usp=sharing

The marked-up version and all prior drafts are still available at the link
previously circulated.

If there are any further refinements, corrections, etc., please put them
into new, clean version on Google Docs, or add them to the clean document
attached here and send it back to the list.

Thanks!

Greg
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