31 CFR § 560.518 - Transactions in Iranian-origin and Iranian government property.

Date issued: Nov. 05 2018

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TURBOFAC Commentary (712 words)

Notes:

1) This GL, specific to the ITSR, is designed primarily to temper the extreme breadth of 560.206, which prohibits, inter alia, transactions "related to" goods of "Iranian origin." This has been interpreted to mean all goods of Iranian origin, even ones that are 800 years old and are not actually located in Iran (see generally 560.206, and comments thereto).

2) 560.518(a): RELATIONSHIP TO ENTITIES SUBJECT TO THE ITSR SOLELY AS A RESULT OF 560.215


Subsection (a), applicable to "domestic transactions," effectively permits dealings in "Iranian origin" goods subject to 560.206 that were in the U.S. prior to the start of the Iranian embargo (but see comment 3, below). The advent of 560.215 (subjecting foreign subsidiaries of U.S. companies to the ITSR prohibitions) may appear...