Case No. MUL-2017-345308-1

Date issued: Feb. 05 2019

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TURBOFAC Commentary (195 words)

Notes:

1) This is the only guidance letter in the Research System concerning the scope and operation of the ITSR-specific “diplomatic pouches” GL. The guidance letters is notable insofar as the language of the GL addresses exports to Iran by U.S. persons or from the U.S., but the letter appears to be about non-U.S. persons exporting items on the CCL (where re-export is prohibited by 560.505 of the ITSR). OFAC says that “[t]o the extent necessary, [the GL] also authorizes the shipment of such goods or technology by the third-country government to Iran via a diplomatic pouch,” implying that where the only U.S. nexus is the item being subject to 560.205 where the re-export is not from the U.S. or by a