Case No. IFSR-2014-314645-1

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TURBOFAC Commentary (1046 words)

Notes:

1) BACKGROUND

As of 7-6-23, Case No. -2014-314645-1 is the only interpretive guidance letter in the Research System with a case ID that relates to a secondary sanctions program (i.e. the IFSR). Consistent with other letters in the Research System that respond to inquiries clearly aimed at secondary sanctions concerns on the part of the applicant, the letter is illuminating more for what it declines to say, rather than what it says.

First, note that, in May of 2013, “Al Hilal Exchange and Al Fida International General Trading, which are based in the United Arab Emirates, were designated pursuant to Executive Order (E.O.) 13382 for providing financial services to previously designated Iranian banks. They have been used by Iran in an attempt to maintain access to foreign currency exchange.” Also, the

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Case No. IFSR-2014-314645-1

TURBOFAC Commentary (1046 words)