Notable Fed. Reg. Notice (OFAC) - FR Notice Explaining Certain TSRA-Related Amendments to the ITSR; Change to Definition of Iranian-origin Goods (81 FR 94254, Dec. 23, 2016)

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TURBOFAC Commentary (644 words)

Notes:

1) OFAC explained in the FR notice announcing the change to the definition of “Goods of Iranian Origin” and “Iranian-Origin Goods” that:

"[t]o address inquiries from the regulated public, including with regard to the status of goods on vessels and aircraft, OFAC also is amending the definition in § 560.306 of the terms goods of Iranian origin and Iranian-origin goods to clarify that this definition does not include certain categories of goods, provided that such goods were not grown, produced, manufactured, extracted, or processed in Iran."

When OFAC phrases an amendment as a "clarification" to a previous provision, the implication is that it considers the amended provision to be no broader or narrower than the provision amended, just more detailed concerning the scope of the provision. In other words, the implication here is that the definition of "Iranian-origin goods" always excluded goods...

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FR Notice Explaining Certain TSRA-Related Amendments to the ITSR; Change to Definition of Iranian-origin Goods (81 FR 94254, Dec. 23, 2016)

TURBOFAC Commentary (644 words)