Case No. IA-2019-362796-1

Date issued: Sep. 17 2019

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TURBOFAC Commentary (772 words)

Notes:

1) For certain relevant background, see https://www.cfr.org/event/conversation-mohammad-javad-zarif (Iranian foreign minister Zarif giving a speech/interview in the U.S. to the CFR in 2017). At the time the CFR's hosting of Zarif in 2017, he was sanctioned pursuant to the ITSR only (as a person resident in Iran and meeting the regulatory definition of "Government of Iran" when speaking in his government capacity). As is evident from the first paragraph of the guidance letter, the CFR was planning on hosting Zarif again in September of 2019 (i.e. the time of the 74th session of the United Nations General Assembly), but he was designated pursuant to EO 13876 on July 31, 2019, not long before the CFR intended on having him return. Note here...