Case No. IA-16124-1

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (260 words)

Notes:

1) “Heat recovery steam generators” are large, complex machines as described at https://en.wikipedia.org/wiki/Heat_recovery_steam_generator. The applicant here is a non-USP not subject to the that wants to export Indian-origin HRSGs to India but has a “technology collaboration agreement with…a U.S. company, for the design and manufacture of the HRSGs” which entails the providing technology, design, and engineering support. OFAC determines that, as it relates to the prohibition at 560.205 on re-exports of items to Iran, the HRSGs could be exported to Iran without violating that prohibition “[t]o the extent that U.S. origin content is incorporated into a foreign-made product outside the United States, and the proposed reexport otherwise satisfies the de minimis conditions of ITSR sections 560.205 and

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Case No. IA-16124-1

TURBOFAC Commentary (260 words)