Case No. IA-2019-359841-1

Date issued: Oct. 10 2019

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TURBOFAC Commentary (442 words)

Notes:

1) Abermay Ltd. is a small/one-person UK-incorporated entity (abermay.co.uk) that specializes in "intellectual property management & consulting". This request for guidance appears aimed solely at receiving confirmation that U.S. banks can be involved in payments related to certain Iran-related IP transactions.

OFAC's guidance recounts 560.509(a) of the ITSR, "authorizing" a variety of IP-related transactions without anything specifying that those transactions must have a U.S. nexus, and 560.516, which is the GL for funds transfers "ordinarily incident and necessary to give effect to, an underlying transaction that has been authorized by a specific or general license..."

OFAC appears to confirm in its conclusion that U.S. banks may be involved in the "receipt of payment of fees from [UK entity's] clients in connection with the provision of intellectual property...