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License No. IA-2013-303395-1
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: PepsiCo , Inc.
700 Anderson Hill Road
Purchase, NY 10577
Via: Baker Botts L.L.P.
The Warner
1299 Pennsylvania Ave., NW
Washington, DC 20003
Attn:[ ]
[...]
1. Based on your letter dated July 11, 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...
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1) BACKGROUND
Unlike License No. IA-2013-303896-1 and the similar licenses discussed in the comments to License No. IA-2013-303896-1, this license goes beyond the scope of what is contemplated by 560.530 and TSRA more generally, as it relates to the transactions surrounding the goods exportations at issues, in particular "taki[ng] actions under" agreements with counterparties "with respect to safety and quality control in the preparation, packaging, and distribution of [PepsiCo.'s] beverages by its counterparty." Evidently PepsiCo sells concentrate to Iran, and is involved to some extent, with a counterparty, in the on-the-ground cola preparation and bottling process.
2) It is a condition of the license that "The item(s) referenced in Section 1(a)(1), above, must be intended for ultimate consumption as food In Iran," and those items are "soft drink concentrates and water beverage mixtures". This appears to be...