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Case No. IA-2016-333011-1
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[ ]
PO Box 121662
Level 9, Standard Chartered Tower
Emaar Square
Dubai, UAE
Dear Mr. [ ]:
This letter responds to your correspondence dated August 22, 2016 to the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), on behalf of Valeant Pharmaceuticals International, Inc. and its U.S. operations and subsidiaries (collectively, “Valeant”), seeking interpretive guidance regarding the export of U.S.-origin medicine and medical equipment to Iran. Specifically, Valeant seeks to determine whether transactions authorized by section 560.530 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (ITSR), are considered transactions exempt from regulation or authorized by OFAC for purposes of OFAC General License H (“GL H”), which was revoked on June 27, 2018. Specifically, Valeant seeks to determine whether a U.S. person would be permitted to export...
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1) The applicant U.S. person (with its non-U.S. subsidiaries) sought guidance under Iran General License (No. H), which had been revoked by the time OFAC responded. More specifically, the applicant sought “to determine whether a U.S. person would be permitted to export or reexport U.S.-origin medicine to its owned or controlled foreign entity, in compliance with section 560.530(a) of the ITSR, if the U.S. person knows or has reason to know that the owned or controlled foreign entity will reexport the U.S.-origin medicine to Iran while also conducting related activities authorized by GL H but not permitted under section 560.530(a).”
2) Iran General License (No. H) authorized entities subject to the ITSR through 560.215 to engage in certain Iran-related activities...