31 CFR § 560.535 - Winding down of transactions related to letters of credit and brokering services relating to certain foodstuffs and carpets.

Date issued: Jun. 28 2018

TURBOFAC Commentary (124 words)

Notes Common to the Post-JCPOA Winddown GLs (560.534, 560.535, 560.536, 560.537)

1) These four GLs all permit the winding down of activities authorized pursuant to GLs issued in connection with the JCPOA. Accordingly, the scope of all of these GLs mimics the scope of the JCPOA GLs to which they correspond.

Note specific to 560.535 (2019):

1) The GL has expired. The existence of the GL is notable insofar as it demonstrates that OFAC's GL for brokering services in connection with TSRA-related exports (560.533) reflects a position that "brokering services" are outside the scope of 560.405 altogether. Refer to General Comment on the Relationship Between Brokering Sales of Goods and the Scope of Transactions "Ordinarily Incident" to Transactions Authorized (System Ed. Note).