LICENSE No. IA-2015-316156-1 [Application included]

Date issued: Nov. 17 2015

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TURBOFAC Commentary (200 words)

Notes:

1) 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". According to the application, the applicant was "requesting a license to cover activities in Iran for the next two years and an additional two years for publication submission and approval." OFAC did not license "publication submission and approval," given 560.538 and the fact that publication is not prohibited by the ITSR unless it actually involves Iran-related transactions. It would not have necessarily been a stretch to consider the activities authorized here to constitute “[o]ther transactions necessary and ordinarily incident to the publishing and marketing of written publications” for the purposes...