Case No. IA-2016-334843-1

Date issued: Feb. 06 2018

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TURBOFAC Commentary (299 words)

Notes:

1) Applicant U.S. person (BioAgilytix) asks if it can enter into a non-disclosure agreement for what appears to be a set of transactions whereby it would import “chemical compounds” presumably from Iran, and return the compounds with “data and qualitative findings regarding its analysis.” While a substantial portion of the first paragraph of the letter is redacted, the totality of the letter would not make much sense if the import and export of the “chemical compounds” were not from/to Iran. OFAC cites the medicine-related GL at 560.530(a)(3) of the ITSR as a relevant provision, and that authorization covers “conduct of related transactions” with respect to exports of “medicine to Iran,” but OFAC ultimately determines that “the performance of bioanalytical laboratory services…do not constitute the ‘conduct of related transactions’ within the...