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Case No. IA-15544
Honorable Allyson Y. Schwartz
United States House of Representatives
1227 Longworth House Office Building
Washington, DC 20515
Dear Representative Schwartz:
Thank you for your letter dated February 14, 2011 to the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC"), requesting that OFAC reconsider authorizing a shipment of Iranian-origin carpets imported into the United States by Robert Mann Oriental Rugs Inc., on behalf of Woven Legends Restoration, Inc., and seized by U.S. Customs and Border Protection.
As you know, on July 1, 2010, the President signed into law the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 ("CISADA") which, among other things, prohibits the importation of Iranian-origin goods and services into the United States, effective 90 days after CISADA's date of enactment. Sections 560.534 and...
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1) The applicant in Case No. IA-15014 appears to be a U.S. person that deals in Persian carpets, including the repair of such carpets. Persian carpets are “Iranian-origin goods” for purposes of 560.306 and 560.206 if they were made within the borders of the modern state of Iran, even if such carpets have been lawfully (or unlawfully) imported into the U.S. Where Iranian-origin goods are in the U.S., 560.518 authorizes “domestic transactions with respect to” such goods. (See comment to 560.306 and 560.518).
Up through September 29, 2010, there was a GL in the ITR (560.534) that authorized “importation into the United States, from Iran or a third country” of “Carpets and other textile...