ENF 50908 (Cautionary Letter)

Date issued: Jul. 02 2018

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TURBOFAC Commentary (206 words)

Notes:

1) This cautionary letter (p. 42, native PDF) is notable in part for the nature of the transactions that resulted in the letter. See the native PDF file for further details. The individual owner of the entity to which the cautionary letter was issued appeared to engage in numerous (and relatively flagrant) violations of the ITSR, and volunteered to put them on the public record in the context of a civil litigation for breach of oral contract (p. 10, native PDF). Neither the plaintiff nor his lawyer were evidently aware of the fact that transshipments of goods to Iran through the UAE was illegal.

Compare An Unnamed Individual (18). The two cases have quite a bit in common (U.S. person Iranians engaging in ITSR violations in connection with commercial...