General Note on 560.215 and 560.556 of the ITSR; the Relationship Between the Two (System Ed. Note)

Last substantive commentary amendment:
May. 09 2024

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TURBOFAC Commentary (5103 words)

Consolidated Note on 560.215 and 560.556 (System Ed. Note)

1) BACKGROUND

560.215 directly implements Sec. 218 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA). It does not change the definition of "U.S. person," but it makes the ITSR the only IEEPA-based sanctions program that extends the bulk of what is prohibited for U.S. persons to all foreign persons owned or controlled by U.S. persons. Compare 515.329 of the CACR (based on TWEA).

560.556 is a general license that is only applicable when a given transaction is, as a threshold matter, within the scope of the prohibition...