Case No. IA-2018-357507-1

Date issued: Dec. 14 2018

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TURBOFAC Commentary (3006 words)

Notes:

*[Note – on September 10, 2024, Iran Air was designated by OFAC and State pursuant to two different sanctions authorities (https://home.treasury.gov/news/press-releases/jy2570), and “Concurrent with [the] action, international partners are announcing measures which will not allow Iran Air to operate in their territory in the future and are pursuing further designations of Iran- and Russia-based individuals, entities, and vessels involved in the transfer of Iranian lethal aid to Russia.” It is unclear whether this means that the USG would take a different secondary sanctions approach to Iran Air than it has in the past as it relates to civil aviation-related transactions (e.g. refueling in third countries)].

1) BACKGROUND

Case No. IA-2018-357507-1 is one of the few illuminating guidance letters on file concerning the application of secondary sanctions and other designation criteria to above-board, standard international trade...