FR Notice Explaining OFAC's Implementation of Sec. 218 of the TRA (77 FR 75849, Dec. 26, 2012)

Date issued: Dec. 26 2012

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TURBOFAC Commentary (1115 words)

Notes:

This FR notice provides the background explaining OFAC's implementation of Sec. 218 of the TRA, extending liability under the ITSR for certain transactions involving Iran to foreign companies owned or controlled by U.S. persons. The following passages are important as an explanation of how OFAC distinguishes between GLs that relate to offshore conduct that may not necessarily be prohibited in principle, and those GLs of which the scope pertains to activities all of which are within the otherwise applicable prohibitions:

Third, another general license, new section 560.556, is being added to subpart E of the ITSR to authorize an entity owned or controlled by a United States person and established or maintained outside the United States (a “U.S.-owned or -controlled foreign...