Case No. IA-16144; LICENSE No. IA-16144

Date issued: Oct. 14 2011

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TURBOFAC Commentary (123 words)

Notes:

1) The cover letter and associated specific license were issued prior to the implementation, into the ITSR, of the GL for the sales of certain real and personal property (560.543). This cover letter and associated specific license suggest that the opening of a bank account in Iran is covered by 560.405 of the ITSR where it is “necessary to effectuate the [authorized] funds transfer associated with the real estate sale” (at least provided that the account is closed thereafter). Does this have across-the-board applicability in the ITSR, as well as other sanctions programs? OFAC does not appear to have explicitly addressed the relationship between the opening of limited purpose bank accounts and the standard ordinarily incident interpretive provision.