Case No. IA-2018-355540-1

Date issued: Jun. 19 2020

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TURBOFAC Commentary (1205 words)

Notes:

1) BACKGROUND

This important guidance letter, which should be read alongside the coin-related Case No. MUL-2013-305202-1 contains a number of notable determinations, i.e. determinations concerning the meaning of “informational materials,” the scope of the GL at 560.518 of the ITSR, and the meaning of “interest” as it relates to the blocking prohibition.

The applicant is a U.S. person seeking authorization to “Iranian-origin collectible banknotes in the United. States. [The applicant] state[s] that [it did] not intend to ship these notes internationally and that the notes are no longer valid currency,” but OFAC addresses (sometimes implicitly) four different scenarios in its determination. They are as follows:

• The banknotes are shipped abroad and are valid currency (prohibited)
• The banknotes are shipped abroad and they are...