Iran - List of Medical Devices Requiring Specific Authorization (Iran General License)

Date issued: Feb. 02 2017

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TURBOFAC Commentary (634 words)

Notes:

1) Read in conjunction with 560.530(a)(3). This list refers to all of the devices that are excluded from the scope of the Iran agriculture/medical device general license. That GL allows for the export of certain items to certain persons in Iran without the need for a specific license, subject to the "12 month" shipment rule mandated by TSRA for all exports of medical devices to Iran.

The list represents items that are within the scope of the term "medical devices," as defined by TSRA, but because OFAC the list only excludes certain devices from a general license that was issued as a result of OFAC's use of its own discretion, OFAC was able to use its discretion to carve out certain devices from the GL, just as it carved...