Case No. SY-2022-886833-1

Date issued: Apr. 21 2022

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TURBOFAC Commentary (419 words)

Notes:

1) OFAC characterizes the “Tell Minis lustre pottery bowl,” as “Syrian-origin artwork,” and accordingly cites to the informational materials exemption, which covers “artworks”. This is the only item in the Research System acknowledging a “pottery bowl” (or any type of ceramic) as “artwork”. Note that 542.307 states that “[t]o be considered information or informational materials, artworks must be classified under chapter subheading 9701, 9702, or 9703 of the Harmonized Tariff Schedule of the United States,” and while “Ceramic Products” normally fall in chapter 69 of the USHTS, chapter 69 “does not cover… [a]rticles of chapter 97 (for example, works of art).” See https://www.usitc.gov/publications/docs/tata/hts/bychapter/1000c69.pdf.

However, notwithstanding that the item meets the definition of “Information or informational materials,” OFAC says that “it does not appear that a person whose property and interests in property are blocked pursuant to section 542.201(a) of...