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 (1123 words)

Notes:

* On 9-23-22, OFAC replaced Iran GL D-1 with Iran GL D-2. See Iran GL D-2, and comments thereto, for a discussion on the changes between GL D-1 and GL D-2. The comment below has not been amended as a result of the issuance of GL D-2.

* 12-21-22 update - 560.539 has been substantially expanded as of 12-21-22 - comments below do not reflect this.

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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...