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Case No. MUL-2014-306809-1
[***]
Senior Director
PayPal Inc.
95 Morton Street
New York, NY 10014
Dear Mr. Hurst:
This responds to your request on behalf of PayPal Inc., a U.S. company, dated December 13, 2013, as supplemented by your letters dated July 21, 2014 and March 8, 2016, to the Office of Foreign Assets Control (OFAC), requesting interpretive guidance, or a specific license if necessary, on transactions involving [***]. Specifically, you have requested guidance on the applicability of these sanctions to the following transactions:
[***]
The applicability of these sanctions regulations to each of these transactions is discussed below.
Iranian Transactions and Sanctions Regulations
The ITSR, 31 C.F.R. Part 560, generally prohibit the importation into the United States of goods and services of Iranian origin or owned or controlled by the government of Iran. 31 C.F.R. § 560.201. Additionally, section 560.206(a)(1)...
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1) Read in conjunction with Case No. IA-2018-355540-1 (banknotes); Case No. MUL-2013-305202-1 (coins) and Case No. NK-93087 (stamps). Here, Paypal, which is a U.S. person online-based payment processor, requests guidance concerning a variety of coin and stamp-related transactions where those items are issued by blocked sanctioned country governments.
2) INFORMATIONAL MATERIALS IN THE STAMP CONTEXT
With respect to banknotes, OFAC determines that
With respect to stamps, OFAC determines that “Invalid Cuban postage stamps are considered to be informational materials,” while “Valid Cuban postage stamps, however, are not informational materials”. Likewise, “OFAC considers invalid Iranian postage stamps to be informational materials, the importation from and exportation to any country of which are exempt from the prohibitions of the ITSR,” while “Valid Iranian...