31 CFR § 560.201 - Prohibited importation of goods or services from Iran.

Date issued: Oct. 22 2012

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TURBOFAC Commentary (1428 words)

Notes:

i) BACKGROUND

This a typical goods/services import ban, generally of the same scope as the Crimea and NKSR bans on the importation of goods and services, except where interpretive provisions specific to the ITSR provide certain safe harbors, as discussed below.

The ITSR version of the goods/services import, which is now nearly 25 years old, has been the subject of a significant amount of interpretation since its inception. An entire cataloguing of "import"-related issues is beyond the scope of this comment, but we flag certain issues below for consideration and further research:

In general, almost every word of "importation into the United States of any goods or services of Iranian origin or owned or controlled by the Government of Iran" has been subject to an...