Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.
Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).
Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category).
Please contact [email protected] or [email protected] with any questions on search results and efficiency.
Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
1) Read in conjunction with the Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry (August 7, 2015), which was issued in connection with the JPOA but not revoked following the U.S. withdrawal from the JCPOA. That SLP covers that which is licensable here, but also extends to entities designated pursuant to the WMDPSR (formerly Iran Air).
2) As noted in the Third Amended Statement of Licensing Policy on Activities Related to the Safety of Iran’s Civil Aviation Industry (August 7, 2015), all licenses for goods exports are subject to IIANPA, which requires that waivers be granted in connection with all exports to Iran of items listed on the CCL. This limits OFAC's discretion in granting licenses under the SLP. There is reason to believe that 030509-FACRL-IA-06 suggests a more restrictive licensing policy with respect to airline safety-related items than is currently in place, but this is unclear.
3) See 030509-FACRL-IA-06. Exports/Aircraft Safety, and comments thereto, where OFAC interprets this GL quite narrowly. This SLP appears to relate to the U.S. implementing its obligations under the Chicago Convention on International Civil Aviation. A 2006 "Information Paper" presented by Iran to the International Civil Aviation Organization discusses/complains about OFAC's interpretation of this provision [1].
[1] See https://www.icao.int/Meetings/AMC/MA/Directors%20General%20of%20Civil%20Aviation%20Conference%20on%20a%20Global%20Strategy%20for%20Aviation%20Safety%20(DGCA-06)/dgca_06_ip_31_e.pdf
4) Provision amended on 4-26-2023 to change "insure" (typo) to "ensure".