Case No. IA-2017-348861-1

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 (726 words)

Notes:

1) Notable Application of 560.205 Where a Foreign-made Item Contains a -Listed Item

560.205 generally prohibits non-U.S. persons from re-exporting goods to Iran from a third country where such goods were "subject to export license application requirements under any United States regulations in effect on May 6, 1995, or thereafter is made subject to such requirements imposed independently of [the ]..." These goods are described in 560.205(b) as "goods or...subject to export license application requirements," and a microchip listed on the CCL classified 3A991.b.2.a would qualify as one such item. Such items are referred to as "U.S.-controlled content" in the guidance letter (and guidance such as JCPOA Implementation FAQ K-13).

560.205(b)(2) provides that 560.205 does not apply where a "U.S.-controlled"...

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Case No. IA-2017-348861-1

TURBOFAC Commentary (726 words)