Case No. MUL-2016-325089-1

Date issued: May. 23 2017

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TURBOFAC Commentary (297 words)

Notes:

1) See FR Notice Explaining Certain TSRA-Related Amendments to the ITSR; Change to Definition of Iranian-origin Goods (81 FR 94254, Dec. 23, 2016), the FR notice announcing the change to the ITSR described in this letter, and query whether the request for guidance resulted in change to the law.

2) Query whether it is only due to 560.306(b)(1) that goods exported to and re-exported from Iran “by a person traveling to Iran or Sudan and remaining under the ‘effective control’ of the traveler” are not goods subject to the prohibitions of 560.206 of the ITSR once re-exported therefrom. If so, the natural follow-on question is “what about goods exported to Iran in the ordinary course of personal travel that are not exported pursuant to the...