Case No. IA-2017-348861-1

Date issued: Feb. 27 2020

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 (769 words)

Notes:

1) Notable Application of 560.205 Where a Foreign-made Item Contains a CCL-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 ITSR]..." 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"...