ITSR GL D-1 and 560.540 — Scenario Matrix, Associated Comment

Date issued: Nov. 30 2019

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TURBOFAC Commentary (500 words)

ITSR GL D-1 and 560.540 — Scenario Matrix, Associated Comment:

The native file associated with this document (avail. upon request) is an excel table, identifying the scope of ITSR GL D-1 and 560.540 in the context of dozens of differing factual scenarios. Note that is has not been updated in light of the issuance of Iran GL D-2, but the changes to GL D would not appear to disturb the analyses found on the spreadsheet to a significant degree.

The scope and interconnectedness of these GLs is extremely complex. As is evident from the Matrix, there are many significant variables that go into the equation, the altering of any of which can significantly change the analysis of a transaction under the law. The principal ones are i)...