Case No. IA-12133-1

Date issued: Mar. 05 2013

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TURBOFAC Commentary (967 words)

Notes:

1) For background concerning the applicant and the product at issue at the relevant time, see https://web.archive.org/web/20070820144310/http://www.sasims.com/_downloa/brochure.pdf. The applicant non-U.S. person produces the “Internet based SaSiMS software package system” (“Package”) which is used “for aviation maintenance planning, forecasting, and tracking” and would be exported to “the Iranian Air Transport Company,” an Iranian entity owned by NIOC (a Government of Iran entity that at the time was also an NPWMD blocked pursuant to the WMDPSR). OFAC’s determinations are based on its understanding that the software package “contains U.S.-origin goods (including software) and technology” that is listed on the CCL, and the package would be delivered “from servers based...