030509-FACRL-IA-06. Exports/Aircraft Safety

Date issued: May. 09 2003

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TURBOFAC Commentary (600 words)

Notes:

1) This guidance interprets 560.528, which has not changed since 2003 and appears to be aimed at the U.S. fulfilling its obligations under the "Convention on International Civil Aviation."

2) The guidance clarifies that OFAC interprets the term "insure the safety" in 560.528 to be limited to only that which is "directly essential to or exclusively for the operation of U.S.- origin commercial passenger aircraft." It is not clear whether this limited reading of the scope of 560.528 has changed over time.

3) Starting in 2014, OFAC has issued Statements of Licensing Policy "on Activities Related to the Safety of Iran’s Civil Aviation Industry," the third amended version of which was released on August 7, 2015. These statements of licensing policy augment 560.528, in particular insofar as they permitted transactions with Iran Air. Now that Iran Air...