Case No. MUL-286-1

Date issued: Mar. 08 2017

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TURBOFAC Commentary (678 words)

Notes:

1) AT&T Mobility has “has roaming agreements in place with” Iranian and Sudanese carriers, and “[p]ursuant to these agreements, AT&T Mobility has received a certain number of test SIM cards from the Carriers” where “[t]est SIM cards are exchanged between carriers after a roaming agreement is signed in order to ensure that the service is functioning properly.” The question is whether AT&T Mobility may “engage in the transfer, exchange, use, or disposal of test SIM cards of Iranian and Sudanese origin that are currently in its possession in the United States.”

2) After noting that the prohibitions of the SSR were effectively repealed through a broad GL that mooted the Sudan-related questions, OFAC cites each of 560.508 (ITSR telecommunications GL), 560.518(a) (“[a]ll domestic transactions with respect to Iranian-origin...