Case No. IA-14861

Date issued: Feb. 13 2013

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TURBOFAC Commentary (366 words)

Notes:

1) Compare Case No. IA-15014 and Case No. IA-15544, concerning the CISADA provision at issue here.

In this case, the timeline is such that:

• September 27, 2010 – Iranian-origin carpets “arrived in the United States”
• September 29, 2010 – OFAC revoked the GLs authorizing the importation of Iranian-origin carpets otherwise prohibited by 560.201
• September 30, 2010 – CBP “released” the Iranian-origin carpets from its custody
• On or around October 20, 2010 – CBP “indicated a violation may have occurred and requested [the] return the carpets”.

OFAC’s conclusion here is that there was no violation of the prohibition on the importation of Iranian-origin goods into the U.S. because 560.534 and 560.535 were still valid as of September 27, 2010. This appears to make clear that...