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CAUTIONARY LETTER
[JAN 31, 2012]
ENF 16021
Dov Ofer
Chief Executive Officer Lumenis, Ltd.
2400 Condensa St.
Santa Clara, CA 95051-0901
Dear Mr. Ofer:
Thank you for your disclosure letters dated March 20, 2006 and March 30, 2007.
This letter serves as notice that the Department of the Treasury's Office of Foreign Assets Control ("OFAC") has completed its review of Lumenis, Ltd.'s ("Lumenis") nine separate exports of medical devices and accessories from the United States to Iran. The Iranian Transactions Regulations, 31 C.F.R. part 560 (the "Regulations"), prohibit the exportation, reexportation, sale or supply of goods, technology, or services to Iran, unless authorized by OFAC or exempted by statute. Accordingly, the transactions between Lumenis and Iran appear to have violated Section 560.204 of the Regulations.
OFAC has chosen to...
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1) Cautionary letter notable in part for its issuance just prior to the five-year statute of limitations for IEEPA-based violations. OFAC will, not infrequently, take many years to close even routine enforcement cases.
2) See the native PDF file for facts surrounding the transactions underlying the letter.