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OFAC Defines Revival Meetings As Services

Posted by at 9:39 pm on November 3, 2010
Category: OFAC • Sudan

RegistrationIn the latest disclosure of civil penalty information by the Office of Foreign Assets Control, the agency describes a Letter of Violation that it issued against an international evangelical group called Christ for All Nations. According to the disclosure, the ministry “exported goods and services to Sudan in support of a non-commercial event in Sudan during 2006.” Another source describes the “non-commercial event” in Sudan as a religious revival rally in Juba:

In the months of July and August 2006 the Christ for all Nations (CfaN) team traveled to Sudan … In Juba, Sudan the team conducted a crusade and fire conference. The response was amazing with over 243,532 people completing a decision card for salvation. The effort required to get to Juba by the technical team was nothing short of heroic. A 1500 kilometer journey over rough roads, and bridges barely able to hold the weight of the huge trucks.

This is probably the first time OFAC has gone after anyone for conducting a church service in a sanctioned country.

Of course, you have to scratch your head to figure out how an overland trip by a German evangelist to a remote area of Sudan to preach violates any of the necessary elements of a violation set forth in the Sudanese Sanctions Regulations. Under Section 538.507, the re-export by non-U.S. persons subject to license requirement under the EAR with less than 10 percent U.S. content and EAR99 items is not prohibited by the regulations. All the goods here came to Sudan by road from other parts of Africa which makes one wonder which of these goods, if any, met these requirements.

And regardless of one’s belief about the efficacy of the services provided at a religious rally, these hardly seem to be “services” in any traditional sense. And even if they are, what regulatory policy is furthered by defining them as such? Does a religious rally in Juba benefit the Sudan-regime in any way that is contrary to the foreign policy interests of the United States?

No fine was imposed by OFAC based on “the licensable, non-commercial nature of the conduct and the non-profit nature of the violator on the other hand.” But is anyone else troubled by the notion that OFAC should be licensing religious services in foreign countries?

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5 Comments:

What’s a “crusade and fire conference”? Could OFAC’s decision to sanction them be based on the nature of the goods that were taken?

Comment by JMH on November 4th, 2010 @ 9:47 am

Unfortunately, this is not the first time OFAC has punished evangelical missionary efforts. OFAC has penalized a number of evangelical Christian missionary organizations, including the Free Will Baptist Missionary organization headquartered in Nashville, for supporting missionaries in Cuba. It would appear that there have been no similar enforcement actions against Catholic organizations that receive support from US contributors.

Comment by Hillbilly on November 4th, 2010 @ 9:49 am

@JMH It could have been based on export to Sudan of goods that were not EAR99 and had more than 10 percent U.S. content. There is no indication that OFAC had any evidence that such goods were involved. Moreover, the goods got to Sudan via a 1500 km route by truck through Africa. How likely is it that there were any non-EAR99 goods with more than 10 percent U.S. content carried over this route to a revival meeting in Sudan?

Comment by Clif Burns on November 4th, 2010 @ 9:52 am

It is almost against the law to mention “Christ” here in our ‘used to be’ christian nation. Maybe now the OFAC is trying to stop the mention of “Christ” for everyone. It is a scary fact. Was the international evangelical group called ‘Christ for All Nations’ under suspect by OFAC? If
that were the case, then it can be understood about their precautions.

Comment by Nova on November 4th, 2010 @ 10:14 am

Unfortunately, this chain indicates a fundamental problem with OFAC’s communications. I can’t imagine OFAC having taken any of the suggested positions above. BUT, why should the regulated public not get clear, concise information from OFAC on the facts and the conceptual framework involved in a penalty action by the government? The only posted examples of “interpretive rulings on OFAC policy” on OFAC’s website end in 2004 ((plus an OFAC-initiated 2006 policy statement). The “partnership” of OFAC with the business community is totally unidirectional, lacking the openness needed to ensure that business (1)understands its role in sanctions and (2) is assured that OFAC is seeking the least restrictive, least anti-competitive implementation strategies consistent with the expected value added of sanctions to foreign policy effectiveness. Better OFAC communication might have avoided the suggestions of anti-Christian or anti-religious bias made above.

Comment by Ex-OFAC on November 4th, 2010 @ 4:23 pm