Case No. IA-2017-346590-1

Date issued: Jul. 31 2018

Last substantive commentary amendment:
May. 17 2024

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (1302 words)

Notes:

1) The applicant here is a non-U.S. person, and while OFAC does not mention 560.215, it appears to be assumed that the applicant is also not owned or controlled by a U.S. person (compare Case No. IA-2017-348861-1; similar analysis where OFAC references 560.215). The question is whether the non-USP can export a “Hewlett-Packard Z840 Workstation…and nVidia Tesla K40 GPU” to Iran.

2) The Meaning of “Personal Computing Device” for GL D-1 Purposes

The “Workstation” is at issue is a tower computer (with no monitor) within the “HP Z” series of “professional workstation computers”.

At the time this guidance was issued, Iran GL D-1 authorized the “exportation, reexportation, or provision, directly or indirectly, to Iran” of “hardware…subject to the EAR” specified in the Annex to the GL, where the Annex included:

Laptops, tablets, and