License No. IA-2013-302591-1

Date issued: Jul. 18 2013

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TURBOFAC Commentary (662 words)

Consolidated Comment on License No. IA-2013-303896-1, License No. IA-2013-302584-1, License No. IA-2013-302591-1, License No. IA-2013-303515-1

1) These four licenses are similar in most respects as boilerplate one-year specific licenses issued pursuant to 560.530, with the one-year requirement reflecting the requirements of TSRA. TSRA, which required OFAC to authorize exports of TSRA-eligible goods, but, pursuant to 22. U.S.C § 7205(a), only pursuant to specific licenses in the case of Iran and other specified countries.

2) The licenses are notable insofar as they provides implicit statements as to what OFAC considers TSRA to require, and those statements have cross-programmatic implications for all programs for which TSRA requires OFAC to license exports of TSRA-eligible goods. For example, it is evident that OFAC does not interpret TSRA to require it to permit...