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License No. IA-2013-302591-1
IRANIAN TRANSACTIONS AND SANCTIONS REGULATIONS
LICENSE
(Granted under the authority of one or more of 22 u.s.c. § 2349aa-9, 50 u.s.c. §§ 1601-51, 1701-06, Executive Orders 12957, 12959, 13059, and 13599, and 31 C.F.R. Parts 501 and 560.)
To: Sysmex Europe GmbH
Bornbarch 1
Norderstedt Schieswig-Holstein 22848
Germany
[...]
1. Based on your letter dated June 12, 2013, to the Office of Foreign Assets Control (the "Application"), and information otherwise available to the Office of Foreign Assets Control, the transactions and activities delineated herein are hereby authorized.
2. This License is granted upon the statements and representations made in the Application, otherwise filed with or made to the Treasury Department as a supplement to the Application, or based on information otherwise available...
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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...