Case No. IA-2023-XXXXXX-1 (June 6, 2023)

Date issued: Jun. 23 2023

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TURBOFAC Commentary (217 words)

Notes:

1) As of 7-4-23, this is the only guidance letter in the Research System in which OFAC confirms that (i) a U.S. person can, without authorization, establish an NGO for the specific purposes of engaging in sanctions-implicating activities, and (ii) that that the NGO GL applies to entities whose sole mission is to raise funds for ultimate transfer to Iran (albeit “for the benefit of the Iranian people”). Other letters in the Research System appear to confirm that the NGO GL applies to very small / new entities, but this one, dealing with a person writing about an entity that is not yet in existence, really drives the point home.

2) Letter confirms that Iran GL E reporting requirement does not kick in until the $500,000 funds transfer threshold would be reached, but it is still not...