FAC No. IA-145905

Date issued: Jul. 14 1995

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TURBOFAC Commentary (251 words)

Notes:

See pp. 12-13 of the native PDF file for the text reproduced here.

The context of the memo from OFAC's then-Director Newcomb is inter-agency debate over how EO Executive Order 12959 of May 6, 1995 should be interpreted. The export ban in section 1 of EO 12959 was "consolidated" in section 2 of EO 13059, which serves as the basis for the bulk of the Iran embargo that is implemented by the ITSR.

On procedure, the memo (in the context of the other items in the PDF) is notable as an example of behind the scenes, inter-agency squabbling over the meaning of OFAC-administered sanctions laws. The OFAC director complains that the process of seeking policy guidance from...