Case No. IA-2013-302015-1; License No. IA-2013-302015-1 [Application and cover letter included]

Date issued: Mar. 14 2014

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TURBOFAC Commentary (574 words)

Notes:

1) Compare LICENSE No. IA-2015-316156-1 (similar). This specific license (with associated application) illustrates OFAC's favorable licensing policy for academic work in Iran, and at the same time illustrates the limits of the scope of the GL (560.538) for "transactions necessary and ordinarily incident to publishing". As with LICENSE No. IA-2015-316156-1, OFAC draws a distinction between “collaboration” with persons directly involved with publications, like editors and co-authors, and the subjects of research, such as the "ordinary Iranians" at issue here.

2) While OFAC acknowledges that the "personal laptop" would not require authorization in light of GL D-1, it is notable that OFAC authorizes, "to the extent authorization is required, exporting to Iran and importing into the United States an EAR99 recording device for the purpose of collecting data for [the] research" at issue. It is possible that the “to the extent authorization...