FAC No. IQ-214841 [Application Included]

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TURBOFAC Commentary (458 words)

Notes:

1) This letter illustrates OFAC's practice of disavowing jurisdiction over once-prohibited transactions once the underlying authority for OFAC's jurisdiction has been revoked.

The revocation of an underlying authority will not prevent OFAC from enforcing violations of once-in-force sanctions regulations, but OFAC stops issuing licenses and providing guidance on the interpretation of provisions for which there is no longer a legal basis for OFAC’s jurisdiction.

2) In this case, the applicant requested an interpretation of Iraqi General License - Section 575.533 of the now-removed Iraqi Sanctions Regulations (Part 575). 575.533 authorized, as of May 23, 2003, all transactions that were otherwise prohibited by the Iraqi Sanctions Regulations, with certain exceptions, including transactions prohibited by 13315.

One type of transaction that was authorized by 575.533 was the importation of Iraqi-origin...

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FAC No. IQ-214841 [Application Included]

TURBOFAC Commentary (458 words)