Case No. IA-12784

Date issued: Dec. 01 2009

Last substantive commentary amendment:
Sep. 03 2023

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TURBOFAC Commentary (864 words)

Notes:

* [12-21-22 update - 560.539 has been substantially expanded - comments below do not yet reflect this]

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1) 560.539

The version of 560.539 that was in force from 2006-2012 is a bit different than the version currently in place. See https://www.govinfo.gov/content/pkg/CFR-2009-title31-vol3/xml/CFR-2009-title31-vol3-part560.xml for the 2009 version. Of particular note, the 2009 version specified that "the performance of transactions for the conduct of the official business of the United Nations...in or involving Iran by U.S. persons who are employees or contractors thereof is hereby authorized."

The "in or involving Iran" qualifier no longer exists.

2) "OFFICIAL BUSINESS"

One notable aspect of the letter is it accepts that "logistical re-supply, passenger flights, observation/monitoring, VIP, negotiation liaison, aero-medical/casualty evacuation, and special police support" are all activities that can be within the scope of the "official business" provision....