Reynolds American Inc., Correspondence with the SEC Office of Global Security Risk (2006); LICENSE No. IA-7315

Date issued: Oct. 13 2006

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (291 words)

Notes:

1) Notable illustration of where the "general inventory" or "warehouse rule" is not applicable. Here, a U.S. corporation entered into an agreement with a non-U.S. company pursuant to which the non-U.S. company would distribute U.S.-made cigarettes throughout the world. While all indications are that the sales to Iran would be a comparatively minor portion of the overall sales made pursuant to the agreement, some sales to Iran were nevertheless specifically contemplated, and the non-U.S. party had a Dubai-based distributor in place to re-export a portion of what was manufactured to Iran [1]. This meant that, minor as the overall degree of sales may have been to Iran, the warehouse rule was not available because, in spite of the lack of "predominance" of the dealings between the non-U.S. person and Iran, at least some of the products were "intended specifically" for Iran. That OFAC needed to license...